Privacy policy
Last updated: August, 2024
Intro
Dinah Holdings Limited (“Company” or “we”) welcomes you. This Privacy Notice (“Privacy Notice”) applies to our website (“Website”).
The Privacy Notice describes which of your personal data Website collects, how stores, processes, and uses it, and what happens when you use the Website.
Content
About us
About you
Personal data
Sources of data
Lawful bases for processing
Visitors’ data
Clients’ data
Data received from third parties
Data sharing with third parties
Data transfer outside the European Economic Area
Data protection
Data subjects rights
European Economic Area residents
United States residents
Do not sell my personal information
Do-not-track requests
Canada residents
Cookies
Privacy Notice updates
About us
We are the controller of your personal data processed through the Website. This means that we determine the purposes and means of personal data processing.
Name | Dinah Holdings Limited |
Registration number | HE409162 |
Address | Prodromou 75, Oneworld Parkview House, 4th floor, 2063, Nicosia, Cyprus |
Email for inquiries |
About you
When you visit the Website, you become our user (“User”).
We divide the Users into categories so you can easily find details about the processing of your personal data. Pay attention that you can fall into several categories depending on your actions.
Type of User | Description |
Registered User | User who has registered on the Website |
Premium User | User who has registered and bought premium subscription |
Visitor | User, who enters the Website without registering an account |
Job Applicant | User who sends a CV through the “Career Page” form on the Website |
Support Requester | User who fills out the “Contact us” form on the Support topic on the Website |
Please note! We do not knowingly process the personal data of Users under the age of consent (under the local law). If you are such a User or the legal representative of such a User, please contact us.
Personal data
Sources of data
We receive your data when you visit the Website and interact with it, depending on your actions on the Website.
You can change your personal data by exercising your right to rectification or by the Website functionality. Please note that the same lawful basis and storage terms apply to the changed data.
We may also (although we do not necessarily do so) receive data from third parties. It depends on your settings and the features you use.
Lawful bases for processing
To process your personal data, we rely on the following lawful bases:
- performance of the contract — for the processing of personal data necessary for the negotiating on, conclusion, and performance of a contract (mainly, the Use of Services) with you;
- legitimate interest — for the processing necessary for the development of our services, taking into consideration your interests, rights, and expectations;
- legal obligation — for the processing as required by applicable laws (for example, to comply with tax or KYC/AML regulations) or if requested by a law enforcement agency, court, supervisory authority, or another state-authorised public body;
- consent — for additional specific purposes.
If we collect personal data on the basis of legitimate interest or performance of the contract, we can use it for another purpose after checking that the new purpose is compatible with the original purpose.
When your data processing is based on a legal obligation or performance of the contract, you are obliged to provide your personal data. We need this data to comply with legal requirements or to properly provide you with our services. The failure to provide such data may have negative consequences, such as tax liability, inability to enter into a contract or provide services to you, etc.
Visitor’s data
When you visit the Website, we collect some data automatically. We collect some technical data about the Users to optimise performance, debug issues, and enhance features while ensuring security and privacy to improve the overall user experience.
Most of the technical data we collect are anonymous, but some data is associated with your IP address and device ID. Please read about personal technical data below.
Data | Reasons for processing | Lawful basis |
Information about the сoarse location (IP address, country)Technical device information and network information (including IP address, HTTP user agent, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks) | The optimization of the performance, debugging, enhancement of the features’ proper functioning, administering and improvement of the Website | Legitimate interest |
Data storage |
We store the data for 3 years from its collection |
We also need cookies to operate, support, and improve the Website’s functionality.
Data | Description | Reasons for processing | Lawful basis |
Necessary cookies | Information that is necessary for the operation of the Website | Improving your experience of using the Website | Performance of the contract |
Marketing cookies | Marketing information used to match relevant advertising to you | Marketing | Consent |
Preference cookies | Information necessary for operating some services on the Website | The operation of some services on the Website | Consent |
Statistics cookies | Statistical data used to understand how you interact with the Website | Improvement of the Website and analysis of the statistic for other purposes | Consent |
Analytics cookies | Analytical data used to understand how you interact with the Website | Improvement of the Website and analysis of the statistic for other purposes | Consent |
Data storage | |
Cookies | Stored during the expiry period provided in our Cookie Policy. |
Clients’ data
When we collect the personal data:
Data | Reasons for processing | Lawful basis |
Registration Data (such as name, surname, email address, phone number, country, photo) | Services provision | Consent |
Payment Data (payment method, billing address, currency amount, bank card information) | Services provision, Security, Compliance with the law | Performance of the contract |
Communication data (communication method, history of communications) | Support, Business Development | Consent |
Data storage | |
Data processed on the basis of contract performance. | 3 years from the contract termination as defined in Use of Services or until you object the processing |
Data that is processed based on consent. | 2 years or until you withdraw your consent |
Job Applicants’ data
When we collect the personal data:
Data | Reasons for processing | Lawful basis |
Contact data (name, surname, phone, email, current location and\or full address) | Engaging with job applicants regarding job opportunities | Legitimate interest, performance of the contract |
CV data (date of birth, photo, registration data (passport, ID cards), phone number, job titles, education, work experience, academic and professional qualifications, links to your website, social media accounts, portfolio and other) | Engaging with job applicants regarding job opportunities | Legitimate interest, performance of the contract |
Communication and any other data you may additionally provide us in your cover letter\comments or inquiry sections | Engaging with job applicants regarding job opportunities | Legitimate interest, performance of the contract |
Data storage | |
Data processed on the basis of legitimate interest and contract performance | Stored for 3 years from receiving |
If you are not selected for the position you applied for, we will reach out to you regarding the potential storage of your CV in our database for future opportunities. If you do not consent to this, your CV will be deleted from our records. Please note that this will not prevent you from reapplying for any future vacancies posted on our website.
Support Requesters’ data
When we collect the personal data:
Data | Reasons for processing | Lawful basis |
Email | Address users’ inquiries, enhance support procedures | Legitimate interest |
Message | Address users’ inquiries, enhance support procedures | Legitimate interest |
Data storage | |
Legitimate interest | Stored for 3 years from receiving |
Sensitive and Minor’s data
We do not intentionally collect sensitive categories of personal data, which may reveal ethnicity, nationality, gender, political and regional beliefs, health and any other categories constituted sensitive by law. Please, avoid mentioning such data categories in your account. If you believe you have mistakenly shared the sensitive data, please let us know at: [email protected], so that we will be able to destroy it within the shortest timeframes.
Our Website is neither designed nor directed to the persons under the age of consent (under the local law). In the event that we become aware of a user, who is considered not to be of legal age, to send us their personal data, we will immediately destroy such data. If you believe a minor has shared their personal data with us, please contact us at: [email protected]
Data sharing with third parties
We can share your personal data with third parties without any harm to you and in full compliance with applicable law. In addition, we have implemented organisational and technical measures to ensure the security of personal data during data transfer to third-party.
Third parties | Description |
Analytics tools | We use analytics tools to understand and promote our business. |
Payment services | We use payment services to process your payments and other transactions. |
Social networks | We use various social networks to spread information about our activities. |
Messengers | We use messengers to communicate with you in ways that are convenient for you. |
Data storage services | We use various cloud services that allow us to securely store data on remote servers. |
Contractors, services providers on Website | We cooperate with service providers and contractors to provide you with their services, operate, develop and improve the features and functionality of the Website, fulfil your support requests, complete payment transactions, etс. |
Providers of the services our team use | We use CRM systems, messengers, and other services in our organisation to provide you with our services. |
State authorities, courts, law enforcement agencies, etc | We may be obliged to transfer some of your data to tax authorities, courts, law enforcement agencies, and other governmental bodies: to comply with a government request, court order, or applicable law; to prevent unlawful use of the Websit0065; to protect against claims of third parties; to help prevent or investigate fraud. |
To get a detailed list of the third-party recipients of your personal data, please reach us at [email protected] .
To share your data, we rely on the following lawful bases, depending on the case: consent, compliance with the law, and performance of a contract.
Data sharing outside the European Economic Area
The personal data we collect is stored in the Netherlands.
We may share personal data with the recipients of other countries, including non-EEA ones, ensuring that your data is protected and processed in accordance with the General Data Protection Regulation.
To share the data outside the EEA, we rely on the adequacy decision by the European Commission or the Data Privacy Framework participation of the recipient.
If the recipient does not participate in the Data Privacy Framework and its country is not deemed to provide an adequate level of protection for your personal data, we adopt Standard Contractual Clauses based on legislation assessments for data protection during transfer and storage.
Data protection
We apply a variety of security measures appropriate to the possible risks.
Organisational measures | |
Staff training | Internal policies and instructions |
Non-disclosure agreements (NDA) | Transfer protection |
Access control mechanism |
Physical measures | |
Video monitoring | Signalling |
Limited access to premises | Round the clock security |
Technical measures | |
Two-factor authentication | Backups |
Firewalls | Encryption of data |
Implementation of HTTPS | End-to-end encryption |
Data subjects rights
You, as a data subject (individual), have the right to interact with your data directly or through a request to us. This section describes these rights and how you can exercise them depending on your residency.
European Economic Area and United Kingdom residents
Right | Description |
Right to access | You can request information on whether personal data are being processed, and, where that is the case, access to this personal data and the information required by law. |
Right to rectification | You can change the data if it is inaccurate or incomplete. |
Right to erasure | You can send us a request to delete your personal data from our systems. We will remove them unless otherwise provided by law. |
Right to restrict the processing | You may partially or completely prohibit us from processing your personal data in cases provided by law. |
Right to data portability | You can request all the data you provided to us and request to transfer data to another controller. |
Right to object | You may object to the processing of your personal data that is collected on the basis of legitimate interest. |
Right to withdraw consent | You can withdraw your consent at any time. |
Right to file a complaint | If your request was not satisfied, you could file a complaint to the regulatory body. |
To exercise your rights, please reach us at [email protected].
For EEA residents: We will answer your request within one month. If your request is not satisfied, you can submit a complaint to your local Data Protection Authority. You may find it here.
For UK residents: We will answer your request within one month. If your request is not satisfied, you can submit a complaint at the Information Commissioner’s Office via number 0303-123-1113 or go online at www.ico.org.uk/concerns.
United States residents
Your rights vary depending on the state of your residency, as indicated below.
Right | Description | Area |
Right to access | You can request an explanation of the processing of your personal data. | California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia. |
Right to correct | You can change the data if it is inaccurate or incomplete. | California, Colorado, Connecticut, Delaware, Indiana, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Virginia. |
Right to delete | You can send us a request to delete your personal data from our systems. | California, Colorado, Connecticut, Delaware, Indiana, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia. |
Right to portability | You can request all the data you provided to us and request to transfer data to another controller. | California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia. |
Right to opt out of sales | The right to opt out of the sale of personal data to third parties. | California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia. |
Right to opt out of certain purposes | The right to opt out of processing for profiling/targeted advertising purposes. | Colorado, Connecticut, Delaware, Indiana, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia. |
Right to opt out of the processing of sensitive data | The right to opt-out of processing of sensitive data. | California. |
Right to opt in for sensitive data processing | The right to opt in before processing sensitive data. | Colorado, Connecticut, Delaware, Indiana, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Virginia. |
Right against automated decision-making | A prohibition against a business making decisions about a consumer based solely on an automated process without human input | California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Virginia. |
Private right of action | The right to seek civil damages from a controller for violations of a statute. | California. |
To exercise your rights, please reach us at [email protected] .
We will answer your request within 30 to 60 days, depending on the state and legislative requirements. If your complaint is not satisfied, you can submit a complaint to the Federal Trade Commission.
Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law. If your state is not on the list, please contact us.
Do not sell my personal information
California residents have the right under the California Consumer Privacy Act (“CCPA”) to opt out of the “sale” of their personal information by a company governed by CCPA.
bo3 does not sell your personal information to anyone nor use your data as a business model.
However, we support CCPA by allowing California residents to opt out of any future sale of their personal information. If you would like to record your preference that we will not sell your data in the future, please contact us via [email protected].
Do-not-track requests
California residents visiting the Website may request that we do not automatically gather and track information about their online browsing movements across the Internet.
Such requests are typically made through web browser settings that control signals or other mechanisms that allow consumers to exercise choice regarding collecting personal data about an individual consumer’s online activities over time and across third-party websites or online services.
We currently do not have the ability to honour these requests. We may modify this Privacy Notice as our abilities change.
Cookies
We use cookies that are needed for the Website’s operation. By using cookies, we receive automatically collected data. You can read more in the Cookie Policy.
If you want to turn off cookies, you can find instructions for managing your browser settings at these links:
Privacy Notice updates
This Privacy Notice is developed according to the General Data Protection Regulation, other applicable privacy laws, and best privacy practices.
Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on the Website.
If there are material changes to the Privacy Notice or the Website that affect your data privacy rights, we will notify you by displaying information on the Website and, if necessary, ask for your consent.
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