PRIVACY POLICY

 

LAST UPDATED: [10.27.23]

 

This Privacy Policy (“Policy”) outlines DonutPay’s (“DonutPay”, “we”, or “us”) practices in relation to the storage, use, processing, and disclosure of personal data that you have chosen to share with us when you access the Platform (as defined in the Terms) or use the Services (as defined in the Terms). This Policy, together with our Terms, applies to your use of the Platform.

 

At DonutPay, we are committed to protecting your personal data and respecting your privacy. Please read this Policy carefully to understand our practices regarding your personal data and how we will treat it. The Policy sets out the basis on which any personal data that we collect from you, or that you provide to us, will be processed by us.

 

Unless defined in this Policy, capitalized words shall have the same meaning ascribed to them in our Terms and Conditions, (“Terms”). Please read this Policy in consonance with our Terms.

 

By accessing the Platform, you consent to the collection, storage, use, and disclosure of your personal data, in accordance with, and are agreeing to be bound by this Policy. We will not collect any information from you, except where it is knowingly and explicitly provided by you.

 

1. THE DATA WE COLLECT ABOUT YOU (a) We may collect, use, store, and transfer different kinds of personal data about you in connection with your use of the Services, including but not limited to: (i) identity data such as username and ip address; (ii) contact data such as personal and/or business contact information including your first name, last name, mailing address, telephone number, fax number, e-mail address or any other personal data you provide to us for the purposes of doing business with us; and (iii) usage data, including how you use the Services.

 

2. HOW IS YOUR PERSONAL DATA COLLECTED?

 

We will collect and process the following data about you: (a) Information you give us: This is the information you consent to giving us about you when you use our Services or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Services, share data through the Platform, through other activities commonly carried out in connection with the Services, and when you report a problem with the Services. If you contact us, we will keep a record of the information shared during the correspondence.

 

(b) Information we collect about you and your device: Each time you visit our Platform or use one of our Services, we will automatically collect personal data including technical and usage data. This primarily includes your theme of choice.

 

(c) We may also collect, use, and share aggregated data such as statistical data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under applicable laws. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the Services. 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 Policy.

 

3. HOW WE USE YOUR PERSONAL DATA AND FOR WHAT PURPOSES

 

We respect data protection principles, and process personal data only for specified, explicit, and legitimate purposes for which such personal data were provided. We primarily use your personal data to enable your use of DonutPay and supply the Services requested by you. We may also use your personal data for the purposes provided in this Policy, and the purposes listed below: (a) You understand that when you consent to providing us with your personal data, you also consent to us sharing the personal data with third parties, including the government and regulatory entities, should the need arise under law, in connection with or related to the provision of Services.

 

(b) You are aware that by using and sharing your information on the Platform, you authorize us, our associate partners, affiliates and related third parties to contact you via email, or the Platform. This is to ensure that you are aware of all the features of the Platform and the Services.

 

(c) You are aware that any and all information pertaining to you, whether or not you directly provide it to us (via the Platform or otherwise), including but not limited to personal correspondence such as emails or letters, instructions from you, etc., may be collected, compiled, and shared by us in order to render Services to you and you expressly consent to this. (d) In general, we will not disclose personal data except in accordance with the following purpose or activity:

 

(i) to register you as a user; (ii) to deliver Services; (iii) to manage our relationship with you including notifying you of changes to any Services; (iv) to administer the Services including troubleshooting and system testing; (v) to monitor trends so we can improve the Services; (vi) to perform our obligations that arise out of the arrangement we are about to enter or have entered with you; (vii) to enforce the terms of the arrangement we have with you or any third party; (viii) to comply with a legal or regulatory obligation.

 

4. TRANSFER OF PERSONAL DATA

 

(a) As a part of your use of and to ensure better and seamless delivery of the Services to you, the information and personal data you provide to us may be transferred to and stored at countries other than your home jurisdiction. These countries shall be subject to data laws of their respective countries. We and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it. By using such Service, you expressly consent to this transfer, and agree and acknowledge that we will not be responsible for any additional terms and conditions, policies, and guidelines.

 

(b) By submitting your information and personal data to us, you agree to the transfer, storage and/or processing of such information, and personal data outside the country you are based in, in the manner described above.

 

5. THIRD PARTY SERVICES

 

(a) Our Services may, from time to time, contain services provided by or links to and from the websites of our partner networks, advertisers, and affiliates (“Third Party Services”). Please note that the Third Party Services that may be accessible through our Services have their own privacy policies. We do not accept any responsibility or liability for the policies or for any personal data that may be collected through the Third Party Services. Please check their policies before you submit any personal data to such websites or use their services.

 

(b) Your relationship with these third parties and their services and tools is independent of your relationship with us. These third parties may allow you to permit/restrict the information that is collected. It may be in your interest to individually restrict or enable such data collections.

 

(c) The place of processing information depends on each third-party service provider and you should check the privacy policy of each of the service providers to identify the data shared and its purpose. You will be subject to a third party’s privacy policy if you opt in to receive communications from third parties. We will not be responsible for the privacy standards and practices of third parties.

 

6. COOKIES (a) We use cookies to distinguish you from other users of the Platform and remember your preferences. This helps us to provide you with a seamless user experience when you use our Services and also allows us to improve the Platform

 

(b) We collect data by way of ‘cookies’. Cookies are small data files which are sent to your browser from the Platform and are stored on your computer or device (hard drive). The cookies shall not provide access to data in your computer or device such as email addresses or any other data that can be traced to you personally. The data collected by way of cookies will allow us to administer the Platform and provide you with a tailored and user-friendly service. The cookies shall enable you to access certain features of the Services. Most web browsers and devices can be set to notify when you receive a cookie or prevent cookies from being sent. If you do prevent cookies from being sent, it may limit the functionality that we can provide when you visit the Platform. At present, the only cookies which are collected are theme preferences.

 

(c) Additionally, you may encounter cookies or other similar devices on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by third parties. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Platform, we may collect such information into a file specific to you.

 

7. DATA SECURITY

 

(a) We implement certain reasonable security measures to protect your personal information from unauthorized access and such security measures are in compliance with the security practices and procedures as prescribed under the applicable laws. However, you agree and acknowledge that the above-mentioned measures do not guarantee absolute protection to the personal information and by accessing the Services, you agree to assume all risks associated with disclosure of personal information arising due to breach of firewalls and secure server software.

 

(b) Where you have chosen a password that enables you access to our Services, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

 

(c) We will comply with the requirements of applicable laws in the event of a data or security risk.

 

8. DATA RETENTION

 

You are aware that your personal data will continue to be stored and retained by us for a reasonable period after your use of the Services.

 

9. BUSINESS TRANSITIONS

 

You are aware that in the event we go through a business transition, such as a merger, acquisition by another organization, or sale of all or a portion of our assets, your personal data might be among the assets transferred.

 

10. CHANGE IN PRIVACY POLICY

 

(a) We keep our Policy under regular review and may amend this Policy from time to time, at our sole discretion.

 

(b) The terms of this Policy may change and if they do, the changes will be posted on this page and, where appropriate, notified to you by email. 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 Services.

 

11. YOUR LEGAL RIGHTS

 

YOU HAVE THE RIGHT TO:

 

(a) Access Your Personal Information. You will receive a copy of the personal information we hold about you. Please note that we may request specific information from you to enable us to confirm your identity and right to access. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. If you would like to make such a request, please contact us at our posted email address and include "Access Personal Information" in the subject line.

 

(b) Update Your Personal Information. We aim to ensure that personal information in our possession is accurate, current and complete. If you believe that the personal information about you is incorrect, incomplete or outdated, you may request the revision or correction of that information. We will use reasonable efforts to revise it and, if necessary, to use reasonable efforts to inform agents, service providers or other third parties, which were provided with inaccurate information, so records in their possession may also be corrected or updated. If you would like to make such a request, please contact us at our posted email address and include "Update Personal Information" in the subject line.

 

(c) Object to Processing You may have the right to object to us processing your information in certain circumstances. This right applies when we are processing your personal information based on a legitimate interest (or those of a third party), which you may challenge if you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. However, in some cases, we may demonstrate that we have compelling legitimate ground to process your information or legal obligations which override your rights and freedoms. If you would like to make such a request, please contact us at our posted email address with "Object to Processing" in the subject line.

 

(d) Erasure of Your Personal Information. You may ask us to delete or remove personal information where there is no legal reason for us to continue using it. You also have the right to ask us to delete or remove your personal information where you successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with law. Please note that we may not always be able to comply with your request of erasure for specific legal reasons which we will notify you, if applicable, at the time of your request. If you would like to make such a request, please contact us at our posted email address with "Erasure of Personal Information" in the subject line.

 

If you wish to exercise any of the rights set above, please send a request to our posted email address. We will need you to provide specific information to help us confirm your identity. This is a security measure to help ensure that your personal information is not disclosed to someone that does not have the right to receive it.