Privacy

Privacy policy

In this Privacy Policy, DIVA TECH, a company incorporated under the laws of the United Arab Emirates (registration number DSO-FZCO-8956) (hereinafter referred to as the "Company"), explain how the Company processes your personal data when you visit the website donplaton.com (referred to as the "Platform") and use the services of the Platform.

All personal data is processed in accordance with the Federal Data Protection Act (PDPL), the General Data Protection Regulation (EU) 2016/679 ("GDPR") and/or other national data protection laws.

When you first visit the Platform, we will ask for your consent to the Company's use of cookies in accordance with the terms of this Privacy Policy.

The Platform includes privacy controls that allow you to independently determine how the Company will process your personal data. With privacy controls, you can choose whether or not you want to receive direct marketing communications.

In this Privacy Policy, you will find answers to the following questions:

  1. how the Company uses your data;
  2. when the Company provides your data to others;
  3. how long the Company keeps your data;
  4. what is the Company's marketing policy;
  5. what rights you have in relation to your personal data;
  6. how the Company uses cookies;
  7. Other issues to be taken into account.

In the event of any requests or if you wish to exercise any of your rights under this Privacy Policy, you may submit such requests as described in the "Contact Us" section.

General principles of data protection and privacy

The Company processes all personal data in accordance with the general principles of data processing:

    • lawfully, fairly and transparently in relation to the personal data subject (legality, fairness and transparency);
    • collect and process personal data only for specified, explicit and legitimate purposes and not subject them to further processing in a manner incompatible with these purposes (limitation of purpose);
    • ensure that personal data are adequate, relevant and limited to what is necessary to achieve the purposes for which they are processed (data minimization);
    • to ensure the accuracy of personal data and, if necessary, its relevance (accuracy);
    • to ensure the storage of personal data in a form that allows the identification of personal data subjects for no longer than is necessary for the purposes for which the personal data are processed (limitation of the storage period);
    • process personal data in a manner that ensures adequate security of personal data, including protection against unauthorized or unlawful processing, as well as against accidental loss, destruction or damage, using appropriate technical or organizational measures (integrity and confidentiality).

All information processed by the Company is considered strictly confidential. All information is kept secure and only accessible by qualified and authorized personnel.

  1. How does the Company use your personal data?

This section provides the following information:

    • the categories of personal data we process;
    • where personal data has not been collected directly from you, the source and specific categories of that data;
    • the purposes for which we may process your personal data;
    • legal basis for processing.

So, what personal data do we collect and why?

    1. We process data about your use of  the Platform ("usage data"). Usage data may include your IP address, geographic location, browser type and version, operating system, referral source, duration of visit, page views and navigation paths on the platform, as well as information about the time, frequency and nature of your use of the services Technologies. We process this data to better understand how you use the Platform. The legal basis for this processing is our legitimate interests, namely monitoring and improving the Platform, tracking usage trends, conducting business intelligence and tailoring the services to the individual interests of each user.
    2. We process your account data ("account data"). Account data may include your name, email address, phone number and other data provided by you when registering. We receive this data directly from you. We process account data to ensure the operation of the Platform, to provide our services, to ensure the security of the Platform and services, and to communicate with you. processing is the performance of the Public Service Agreement between the Company and users, as well as our legitimate interests, namely monitoring and improving the Platform and services.
    3. We process information related to the provision of services to you on our Platform ("payment transaction data"). Payment transaction data is processed by the Company only to the extent necessary to provide access to all the functionality of the Platform, including statistical data. The legal basis for such processing is the performance of a contract between you and us and/or taking steps at your request to conclude such a contract as well as our legitimate interests, namely the proper administration of the Platform. The Company does not collect or store your payment data in its entirety, this data is processed exclusively by payment service providers – Payment Providers.
    4. The Company (our Partners – Payment Providers, where required by the relevant legislation) processes information related to anti-money laundering measures (hereinafter referred to as "AML Data"). AML Data may additionally include address or place of residence, identity documents including your photo, documents confirming the source of your income, utility bills and others. request such information in accordance with applicable law in order to comply with the "know your customer" obligations.
    5. We have a dedicated fraud detection  process in place to detect and prevent any fraudulent transactions ("fraud detection data"). To ensure timely detection of risks and fraud, effectively prevent fraudulent transactions, and improve our fraud detection process, we collect and process various account data, transaction data, technical browser information, and device, usage data that allows us to determine whether a user's activities demonstrate suspicious behavior (e.g., whether the user is a bot, whether they have tried to deceive us in the past, and similar signs associated with fraudulent behavior). The legal basis for this processing is our legitimate interests, namely to reduce the number of fraudulent transactions and to comply with the requirements of our partners – Payment Providers.
    6. We may process information that you provide to us in order to subscribe to our e-mails and newsletters ("direct marketing data"). Direct marketing data is processed in order to send you relevant messages and newsletters.
    7. We may process information relating to any communications you send to us ("correspondence data"). Correspondence data may include the content of the message and associated metadata. In the case of communications via the Platform. Correspondence data is processed for the purpose of contacting you and maintaining records. The legal basis for this processing is our legitimate interests, namely the proper administration of the Platform, ensuring that the Platform is consistent and high-quality consulting practices, as well as dispute resolution between you and the Company.
    8. We may process any of your personal data identified in this Privacy Policy where it is necessary to ensure the protection of legal claims, whether judicial, administrative, or extrajudicial. The legal basis for this processing is our legitimate interests, namely the protection of the Company's legal rights, your legal rights and the legal rights of others.
    9. We may process any of your personal data specified in this Privacy Policy if necessary for risk management purposes or to obtain professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business from risks.
    10. In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary to comply with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
       
  2. When do we share your data with third parties?
     
    1. We may disclose your personal data to any member of our group of companies (including our subsidiaries, our ultimate holding company and all of its subsidiaries) to the extent reasonably necessary for the purposes set out in this notice. Such purposes may include internal administrative tasks and the provision/sharing of IT services or data centres within the group.
    2. We may disclose your personal data  to our professional advisers to the extent reasonably necessary for the purposes of risk management, obtaining professional advice, exercising or defending legal claims, whether in court proceedings or in administrative or extrajudicial proceedings.
    3. We may disclose your personal data to our fraud, risk management, and compliance service providers  to the extent reasonably necessary to protect your personal data and comply with our legal obligations.
    4. We may disclose your personal data to our payment service providers – Payment Providers. We will only provide such data to the extent necessary to process your payment transactions and to deal with complaints and requests related to such payment transactions.
    5. We may disclose your personal data to other service providers  to the extent reasonably necessary to provide specific services (including server and maintenance service providers, email service providers, newsletter service providers, consumer review websites and other service providers). We take all reasonable steps to ensure that such subcontractors implement appropriate organizational and technical measures to ensure the security and confidentiality of your personal data.
    6. In addition to the specific disclosures of personal information described in this Section, we may disclose your personal information when such disclosure is necessary to comply with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
       
  3. How long do we keep your data?
     
    1. Your personal data that we process for any purpose or purposes will not be retained for longer than is necessary for that purpose or purposes. In any case, they will be stored no longer:
      1. Account data will be retained for a maximum of five (5) years after your last account activity;
      2. data on payment transactions will be stored for no more than 5 (five) years after the end of the use of the Platform;
      3. Anti-money laundering data will be retained for as long as necessary to comply with relevant legal requirements;
      4. Fraud detection data will be retained for as long as the account details are retained or longer if the user's account is deemed capable of committing fraud;
      5. Direct marketing data will be retained for as long as your account is active, unless you withdraw your consent earlier;
      6. Correspondence data will be stored for a maximum of 12 (twelve) months after receipt of such correspondence.
    2. In some cases, we may not be able to specify in advance the retention periods for your personal data. This means  that the usage data will be stored for as long as necessary for the respective processing purposes.
    3. Notwithstanding the other provisions of this Section, we may retain your personal data for a longer period of time than specified in cases where:
      1. This is necessary for our legitimate business interests, such as fraud detection and prevention and improving security. If the Company suspends your user account for security and fraud prevention purposes, we may retain certain information from that user account to prevent that user from creating a new account in the future.
      2. It is necessary to comply with our legal obligations. The Company may retain some of your information for tax, legal reporting and auditing purposes;
      3. legal disputes need to be resolved;
      4. is necessary to enforce our agreements and/or protect our legitimate interests;
      5. Because we protect the Platform from accidental or malicious loss and damage, copies of your personal information cannot be deleted from our backup systems for a limited period of time.
  1. Marketing messages
     
    1. If you agree, we will send you marketing communications via email and/or leave notifications in your account to inform you of our plans.
    2. In addition, if we have already provided you with services and you do not object, we will inform you about our other products that may be of interest to you, including other related information.
    3. You can opt out of receiving marketing communications at any time.
    4. This can be done as follows:
      1. by selecting the relevant link in any of our marketing communications;
      2. by contacting us using the means indicated in the "Contacts" section.
    5. Upon completion of any of the proposed actions, we will update your profile to ensure that you do not receive future marketing communications from us.
    6. Please note that as our operations are a network of closely related services, it may take a few days for all systems to be updated, so you may continue to receive marketing communications while we process your request.
    7. Opting out of marketing communications will not prevent you from receiving communications directly related to the provision of services, updates to our terms and policies, or other important communications relating to the operation of the Platform.
       
  2. Your rights
     
    1. In this section, we have summarized your rights under data protection laws. Some of these rights are complex, so we are only presenting the main aspects. Therefore, for a full explanation of these rights, you should consult the relevant laws and regulatory guidelines.
    2. Your other basic rights under data protection legislation are:
      1. the right to access personal data;
      2. the right to rectification of personal data;
      3. the right to have your personal data erased;
      4. the right to restrict the processing of your personal data;
      5. the right to object to the processing of your personal data;
      6. the right to withdraw consent to the use of personal data.
    3. The right to access data.  You have the right to confirm whether we are processing your personal data and, if so, to access it, as well as certain additional information. This additional information includes details about the purposes of the processing, the categories of personal data involved and the recipients of the personal data. Provided that this does not affect the rights and freedoms of others, we will provide you with a copy of your personal data.
    4. Right to rectification of personal data. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
    5. Right to erasure of your personal data. In some cases, we will delete your personal data if: (i) it is no longer necessary for the purposes for which it was collected or processed; (ii) you have withdrawn your consent to the processing of the data and there are no other legal grounds for the processing; (iii) you are not subject to certain rules of applicable data protection laws; (iv) the processing is carried out for direct marketing purposes; or (v) the personal data was obtained in accordance with the law. However, there are exceptions to the right to erasure. Such exceptions include where the processing is necessary: (i) for the exercise of the right to freedom of expression and information; (ii) to comply with our legal obligations; or (iii) to ensure the defense of legal claims.
    6. In some circumstances, you have  the right to restrict the processing of your personal data. Such circumstances include: (i) you contest the accuracy of the personal data; (ii) the processing is unlawful but you object to erasure; (iii) we no longer need the personal data for the purposes of our processing, but you need the personal data to establish, exercise or defend legal claims; and (iv) you have objected to the processing prior to the acknowledgement of that objection. Where processing has been restricted for this reason, we may continue to retain your personal data, however, we will only process such data in any other way in the future: (i) with your consent; (ii) to establish, exercise or defend legal claims; (iii) to protect the rights of another person; or (iv) for reasons of significant public interest.
    7. You have the  right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is the need for the processing to: perform a task carried out in the public interest or protect the legitimate interests of the Company or a third party. In the event of your objection, we will stop processing personal data,  unless we can demonstrate that there are legitimate legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is intended to ensure the defence of legal claims.
    8. You have the right to object to the processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will stop processing your personal data for these purposes.
    9. You have the right to object to our processing of your personal data for marketing or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out to protect the public interest.
    10. Where the legal basis for the processing of your personal data is your consent, you have the right to withdraw that consent at any time. The withdrawal will not affect the lawfulness of the processing that took place prior to the withdrawal.
    11. In addition to the specific measures provided in this Section or on the Platform's website, you can also exercise any of the rights indicated herein by contacting us through  the Contact Us section.
       
  3. About Cookies

      We use cookies on our Platform to customize our Platform as much as possible and thereby improve the browsing experience on our Platform.

      What is a cookie?

       A cookie is a small text file placed on your device that allows you to access the features and
       functionality of the Platform. For example, cookies allow us to identify your device and protect
       your access to the Platform. They allow the Platform to store data such as:

    1. Login data (IP address of the login device, time of login, location from which the login attempt was made);
    2. Browser type;
    3. Demographic data (age group, gender);
    4. Data about how you browse the Platform (which sections you visit, which products you are interested in).
       
  2. Cookies we use

      We use four main types of cookies for the following purposes:

    1. Necessary Cookies – These cookies are necessary for the website to function and cannot be disabled in our systems. They are usually set only in response to your actions that constitute a request for services, such as setting up privacy settings, logging in, or filling out forms. You can set your browser to block these cookies or to warn you about their use, but in this case, some areas of the Platform will not work.
    2. Analytical Cookies – These cookies allow us to count visits and traffic sources so that we can measure and improve the performance of the Platform. They help us determine which pages are the most and least popular, as well as track the movements of visitors around the Platform. All information collected by these cookies is aggregated and therefore anonymous. If you do not allow the use of these cookies, we will not know when you visited the Platform.
    3. Preference Cookies – These cookies allow the Platform to remember information that changes the behavior or appearance of the Platform, such as your preferred region.
    4. Marketing cookies – these cookies may be set by our advertising partners through the Platform. These companies may use them to build a profile of your interests and show you relevant ads on other sites. They do not store personal data directly, but are based on the unique identification of your browser and internet device. If you do not allow these cookies, you will see less targeted advertising.
       
  2. How can I control cookies?
     
    1. Most browsers allow you to refuse and delete cookies. The ways to do this vary depending on the browser and its version. However, you can get up-to-date information about blocking and deleting cookies by contacting the support sites of the relevant browser.
    2. Blocking all cookies will have a negative impact on the usability of many websites.
    3. If you block cookies, you may not be able to use all the features of our Platform.