PRIVACY POLICY

DEFINITIONS

Personal data: all information about an identified or identifiable natural person through one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person, including the device IP number, location data, internet identifier and information collected through cookies and other similar technology.
Policy: this Privacy Policy.
GDPR: The Regulation (EU) 2016/679 of the European Parliament and of the Council of 7 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
Platform: website available at: https://digitaldialogllc.com
Customer/User: any physical person visiting the Platform or making use of one or more services or functionalities made available on the Platform.
Controller: Digital Dialog LLC, Registered address: 1209 Orange Street, Wilmington, Delaware 19801, USA.

DATA PROCESSING IN CONNECTION WITH WEBSITE USE

In connection with the Customer's use of the Platform, the Controller shall collect data to the extent necessary to provide the particular services offered on the Platform, as well as information about the User's activity on the Platform. The following describes the specific principles and purposes of the processing of the personal data collected during the User's use of the Platform.

PURPOSES AND LEGAL BASIS OF DATA PROCESSING ON THE WEBSITE

Website use

Personal data of all persons using the Platform (including the IP address or other identifiers and information collected through cookies or other similar technologies) who are not Customers or potential Customers (i.e. persons who have not completed the registration process but have given their consent to the processing of personal data) shall be processed by the Controller:

• for analytical and statistical purposes – then the legal basis for the processing shall be the Controller's legitimate interest consisting in conducting analyses of the Users' activity and their preferences in order to improve the applied functionalities and services provided;
• in order to possibly determine, investigate or defend against claims – the legal basis of such processing shall be the Controller's legitimate interest in protecting their rights;
• for marketing purposes of the Controller and other entities, in particular, related to presenting behavioral advertisement; in order to identify the sender and to handle their request sent via the form provided;

The Controller shall process the Customers' personal data in order to carry out marketing activities, which may consist in:

• displaying marketing content that is not tailored to the User's preferences (including contextual advertising);
• showing the User marketing content corresponding to their interests (behavioural advertising);
• sending email alerts on interesting offers or content that contains commercial information.

Advertising

The Controller and its Partners/Vendors shall process the Customers' personal data, including personal data collected through cookies and other similar technologies for marketing purposes, in connection with addressing advertising to the Users. The processing of personal data for this purpose shall also include the profiling of Users. The use of personal data collected through this technology for marketing purposes, in particular, to promote the services and goods of third parties, may require the User's consent. In this case, this consent may be withdrawn at any time through the relevant privacy settings.

COOKIES AND SIMILAR TECHNOLOGY

Cookies are small text files stored on the device of the User browsing the Platform. Cookies typically contain the name of the website from which they originate, their storage time on the terminal device and a unique number. In this Policy, information regarding cookies hall also apply to other similar technologies used within the Platform.

"Service" cookies

The Controller shall use the so-called service cookies primarily to provide the User with services provided electronically and to improve the quality of these services. For this reason, the Controller and other entities providing analytical and statistical services to the Controller shall use cookies to store information or to access information already stored in the User's telecommunications terminal device (computer, telephone, tablet, etc.).

"Marketing" cookies

The Controller and Partners/Vendors shall also use cookies for marketing purposes, including in connection with addressing advertising to Users. For this purpose, the Controller and Partners/Vendors shall store information or gain access to information already stored in the User's telecommunications terminal device (computer, phone, tablet, etc.). The use of cookies collected through this technology for marketing purposes, in particular, to promote the services and goods of third parties, shall require the User's consent. This consent may be withdrawn at any time through the User's browser settings. If the User does not wish to receive cookies, they should use the browser option available to connect to the Platform and select the automatic decline option. These settings usually also allow the management of cookies.

RULES ON PERSONAL DATA PROCESSING

The period of data processing by the Controller shall depend on the type of service provided and the processing purpose. As a rule, the data shall be processed for the duration of the provision of the service or the fulfillment of the order, until the withdrawal of the consent given, or until an effective objection is raised against the processing of the data in cases where the legal basis for data processing is the legitimate interest of the Controller. The period of data processing may be extended if the processing is necessary for the establishment, investigation, or defense against possible claims, but not longer than for 10 years, and after this period, only in the case and to the extent required by law. After the end of the processing period, the data shall be irreversibly deleted or anonymised.

USER RIGHTS

The User has the right to access the data and to demand their rectification, erasure, or restriction of processing, and has the right to data portability and the right to object to the processing of the data, as well as the right to lodge a complaint with a supervisory authority that is responsible for personal data protection. Insofar as the basis for processing the User's data is consent, the data shall be processed until the consent is withdrawn. The User may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Right to object

The User shall have the right to object at any time to the processing of their data for direct marketing purposes, including profiling, where the processing is carried out in connection with a legitimate interest of the Controller. The User shall also have the right to object at any time to the processing of their data for reasons connected with their particular situation in cases where the legal basis of data processing is the legitimate interest of the Controller (e.g. in connection with the performance of analytical and statistical purposes, including profiling).

DATA RECIPIENTS

Personal data collected by the Controller in connection with the provision of services on the Platform shall be disclosed to external entities, including in particular the suppliers responsible for the maintenance of IT systems used to provide services on the Platform, marketing agencies (in the scope of marketing services), operators of mailing platforms, logistics companies, and entities related to the Controller, including companies in the Controller's capital group.

TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

The level of protection of personal data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, the Controller shall transfer personal data outside the EEA only when necessary, and with an adequate level of protection, primarily by:

• cooperation with entities processing personal data in countries to which a relevant decision of the European Commission has been issued
• use of standard contractual clauses issued by the European Commission;
• the application of binding corporate rules approved by the competent supervisory authority

SECURITY OF PERSONAL DATA

The Controller shall conduct a risk analysis on an ongoing basis in order to ensure that personal data is processed securely, ensuring in particular that only authorised persons have access to the data and only to the extent necessary for the performance of their tasks. The Controller shall ensure that all operations on personal data are recorded and performed only by authorised employees and associates. The Controller shall take all necessary measures to ensure that also its subcontractors and other cooperating entities guarantee the application of appropriate security measures whenever they process personal data on behalf of the Controller.

CONTACT DATA

Contact with the Controller is possible via email – contact@digitaldialogllc.com.

CHANGES TO THE PRIVACY POLICY

This Policy is kept under ongoing review and updated as necessary


The current version of the Policy has been adopted and is effective from 11 September, 2023.