CONFIDENTIALITY POLICY
General provisions
- This document defines the policy of Umap General FZCO regarding the processing of Personal Data of Users of the DaGama service and the DaGama mobile app (hereinafter also referred to as the "Policy") given to us. We will use this information:
- The User shall fully read this Policy before using the DaGama Service in the form of a mobile app and / or website (hereinafter referred to as the "Service"). Using the Service and filling out any forms by the User shall mean full and unconditional acceptance of the Policy by the User.
- This document is publicly available and is available on the official website and in the mobile app.
- DaGama shall be entitled to make changes to this Policy, for reasons related to working practices or regulatory changes, without prior notice to the User and/or obtaining approval from the User. When changes are made, the date of the last revision update shall be indicated in the Policy header. The new version of the Policy shall take effect upon it is posted on the Service, unless otherwise provided by the new version of the Policy. In this regard, we recommend that you read the Policy when you re-visit the Service.
- DaGama may, at its sole discretion, notify the User of the addition and / or modification of this Agreement in the manner that DaGama deems most appropriate. Using the Service, the materials and functions offered on it at any time means that the User unconditionally accepts all the terms and conditions of this Agreement. If the User does not agree with the current version of this Agreement in whole or in part, the User shall immediately request DaGama to delete his account and stop using the Service until his account is deleted.
- Using the Service, the User fully and unconditionally accepts this Policy, including by downloading, installing, using the Service and filling out any forms posted on it, the User confirms his consent to the DaGamaprocessing of Personal Data and other information provided during registration, collected automatically, as well as placed by the User voluntarily on his personal page in the personal account, including, but not limited to User generated content: comments, reviews, descriptions, reviews, design elements, photos, videos, images, drawings, sound files, links to third-party resources.
Purposes for collecting and processing Personal Data
- DaGama collects and / or processes Personal Data when the User uses the services offered by the Service, as well as when using or otherwise interacting with DaGamaproducts.
- DaGama collects and / or processes Personal Data for the purpose of registering the User on the Service, enabling its full use, providing the User with services offered by the Service and other Users, and participating in research and marketing activities conducted by DaGama.
- DaGama collects and stores only Personal Data that is necessary for the provision of the Service or the performance of agreements and contracts with the User, except in cases where the law provides for mandatory storage of Personal Data for a period specified by law, including for the purpose of:
- User identification;
- Providing the User with personalized services;
- Communication with the User, including sending notifications, requests and information related to the use of the Service, the provision of services, as well as processing User's requests;
- Conducting statistical and other research based on depersonalized data;
- Conducting marketing campaigns for Users, including for the purpose of distributing offers to participate in the promotion and receiving prizes/rewards provided for by the promotion;
- Distribution of advertising and information materials over telecommunication networks, including through the use of telephone, Internet, mobile radiotelephone communications, or through direct contacts;
- Resolve disputes and identify problems;
- Prevent potentially prohibited and illegal actions;
- Targeting newsletters, advertising materials and other information brought to the attention of Users.
Volume of Personal Data processed
- As part of this Policy, the User's Personal Data includes:
- Personal Data that the User provides about himself when registering on the Service and selecting the proposed product, such as: first name, last name, gender, date of birth, photos, email address, phone number;
- Data that is automatically transmitted to DaGamaduring the use of the Service using the software installed on the User's device, including: IP address, cookieinformation, information about the User's browser (or other program that allows access to the Service's services), geolocation, access time, address of the requested page, as well as other data, including those provided by the User after registration, during the use of the Service.
- DaGama, for its part, synchronizes the search history, settings, and favorites in the User's personal account.
Procedure and conditions for processing Personal Data
- DaGama shall be entitled to:
- perform any actions (transactions) or a set of actions (transactions) performed using automation tools or without using automation tools with its Personal Data (processing of Personal Data), including collection, recording, copying, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access) to third parties, as well as in cases directly provided for by the applicable law, in compliance with the requirements of information confidentiality, depersonalization, blocking, deletion, destruction of Personal Data, and confirms that by giving such consent, it acts on own accord and in own interest.
- use cookies and similar technologies (including: pixel tags, web beacons, transparent GIF files, JavaScript and local data storage, etc.) to collect personal identification information or information that can become personal identification information in combination with other information, in compliance with all necessary legal requirements regarding the privacy of Users' Personal Data, by identifying Users, counting their number and observing which pages of the Service they visit, to ensure maximum User convenience by providing personalized information, remembering preferences in marketing and products, as well as helping to get the right information (including for entering the protected areas of the Service or for using the personal account, internal modules of the Service functionality), analyzing User's actions on the Service, in order to improve and optimize the Service, including, to make it easier for visitors to find the necessary information on the Service;
- provide advertising, messages and content, including by sending push or sms notifications (messages), advertising notifications and messages, via e-mail on the Internet, using the services and databases of both the Service itself and the services of third-party (external) Services and resources on the Internet;
- communicate directly with the User, including via telephone.
- DaGama may use the User-provided information, including Personal Data, to ensure compliance with the requirements of applicable law (including, for the prevention and/or suppression of Users'illicit and/or illegal actions). Disclosure of the information provided by the User can be made only in accordance with the applicable law at the request of the court, law enforcement agencies, as well as in other cases provided by law.
- Personal Data shall be processed upon the User fills out the appropriate form for providing services on the Service or in the mobile app, or provides Personal Data in another form, and until the termination of the relationship between DaGama and the User as a result of deleting his account, or withdrawing consent to the processing of Personal Data by the person who provided such data in another form.
- DaGama shall be entitled to transfer the User's Personal Data to third parties in the following cases:
- The User has expressed his consent to such actions;
- The User has openly shared his Personal Data with other Users, including by selecting the "visibility for all" function;
- The transfer is required to use a specific function/service of the Service;
- Transfer is provided for by applicable law within the procedure established by law;
- The transfer takes place within the framework of the sale or other transfer of the Service (in whole or in part), while the buyer passes all obligations to comply with the terms of this Policy in relation to the Personal Data received by him.
- DaGama shall not sell or lease Personal Data to third parties for marketing purposes without obtaining the User's permissionon a preliminarily basis.
- Access to Users' Personal Data shall be possible within DaGamaand its employees.
- DaGama shall make every reasonable effort to ensure that:
- Confidential information about Users is collected by DaGama only to the minimum extent necessary;
- Confidential information is used exclusively for the purposes stated when it iscollected;
- Confidential information is not transferred to third parties, except as specified herein or applicable law.
- DaGama shall store Personal Data and protect It from unauthorized access and distribution in accordance with internal rules and regulations. The User's Personal Data shall be kept confidential, except for cases when the Service technology or the software settings used by the User provide for an open exchange of information with other Users of the Service or with any Internet Users.
- The User's Personal Data shall be kept confidential, except for cases when the User voluntarily provides information about himself for general access to an unlimited number of persons.
- DaGama ensures the confidentiality and security of Personal Data when processing it in accordance with the requirements of applicable law. DaGamashall apply appropriate technological and operational security standards to protect information provided by visitors to our Service from unauthorized access, disclosure, distortion or destruction.
- Personal Data shall be stored on the Service until the User stops using the Service. If data is deleted from the Service at the initiative of one of the parties, the User's Personal Data shall be stored in DaGama databases for no more than six months, in accordance with the legislation of the Russian Federation.
- After the above-mentioned period of storage of the User's Personal Data expires, the User's Personal Data shall be destroyed. Personal Data shall be destroyed by erasing information using certified software with guaranteed destruction (in accordance with the specified characteristics for the installed software with guaranteed destruction).
- The User's Personal Data shall be kept by DaGama exclusively on electronic media and processed using automated systems, except for cases when non-automated processing of Personal Data is necessary in connection with the implementation of the requirements of the applicable law.
- The User agrees that images placed by him within the service can be used by DaGama on other DaGamaservices and resources, as well as in advertising or marketing materials posted on DaGama resources on the Internet to attract the attention of other Users to the Service or to otherDaGama resources and services, both with stating their author (the author's name will be specified as the name of the User, which he specified during registration), and without it, without the need to obtain special User's permission and without paying royalties. If the User does not have the right to grant DaGama the right to use any image in the specified ways, he shall refrain from downloading such an image.
- The User understands and does not object to the fact that DaGamais an international company operating in many countries of the world. The transfer of information outside the User's country and its subsequent protection shall be carried out in accordance with this Provision, as well as applicable law.
User's right
- The User can at any time change (update, supplement) the Personal Data provided by him or part of it, as well as the parameters of its privacy, using the function of editing Personal Data in the personal account.
- The Usershall be entitled to withdraw the consent to the processing of Personal Data at any time, subject to written notification to DaGama via the communication channels specified on the Service in the "Help" and "Contacts" section, at least 30 days before the expected date of termination of processing and use of the Personal Data provided.
Final provisions
- The Service may contain links to Services and other information resources of third parties on the Internet, placed solely for the convenience of Users. DaGama shall not provide its approval and shall not give any estimates of third-party Services or information contained on these Services, as well as possible results of their use, as well as shall not check the accuracy and relevance of this information. The User shall be solely responsible for using third-party Services.
- This Policy shall apply only to the services of the Service. DaGamashall not control and not be responsible for the services and offers of third parties to which the User can click on links available from the services of the Service, including information about the User processed by third parties.
- The User shall be solely responsible for the security (resistance to selection) of the means chosen by him for accessing the account, and also independently ensure their confidentiality. The User shall be solely responsible for all actions (as well as their consequences) within or using the Service's functionality under the User's account, including cases where the User voluntarily transfers data for accessing the User's account to third parties on any terms (including under contracts or agreements). In this case, all actions within or using the services of the Service under the User's account shall be considered to be performed by the User himself.
- Individuals who process Personal Datashall comply with the requirements of DaGama regulatory documents in terms of ensuring the confidentiality and security of Personal Data.
- The Service is not intended or not specifically intended for use by persons under the age of 18. The Policy shall not provide for the intentional collection or storage of Personal Data of persons under the age of 18.
Umap General FZCO
IFZA Business Park, DDP, 001 – 27923, Dubai, United Arab Emirates
Last edited: November 01, 2023 (v. 1. 0).