PRIVACY POLICY

This Privacy Policy outlines how Digital Dialog LLC with its registered seat at 1209 Orange Street, Wilmington, Delaware 19801 (hereinafter referred to as the “Data Controller”, “Company”, “Us”) of this website, processes, discloses and protects personal data sent and retrieved through https://digitalassistance24.com/ website (hereinafter referred to as the “Website”).

By using our Website, you consent to our collection of data necessary to provide our services.

1. BASIC INFORMATION ON DATA PROTECTION

2. COMPLIANCE WITH EU REGULATION AND UNITED STATES

1. 1. Company is fully compliant with regulations governing the protection of personal data and, in particular, with GDPR, in such a way that any personal information supplied by the party concerned (hereinafter the “Data Subject” or “Users”) when requesting a specific service for which he/she provides us with his/her data through this Website shall be processed in compliance with the legally enforceable safeguards and obligations.

1. 2. If you are a California or Virginia resident, the information below applies to you and supplements the information provided above. Certain information collected on this Website, including your log-in and password, may constitute “sensitive personal information” as that term is defined by California or Virginia privacy law. However, the Company only uses such information to provide services and products subject to our services or as otherwise permitted under California and Virginia privacy law. If you choose to exercise the rights set out in this Privacy Policy, you also have the right to not receive discriminatory treatment for exercising these rights.

3. CATEGORIES OF DATA

   1. The Data Controller does not provide a list of Personal Data types collected. Data sent and retrieved through this Website may include both publicly available and non-publicly available data, including Personal Data of Website Users.

   2. The Personal Data of Website Users sent and retrieved through the Website may include:

      • first name and surname,

      • address,

      • email address,

      • telephone number,

      • content of the message attached to gifts,

      • payment status,

      • information about purchases subject to support services

      • all correspondence conducted with Website Users.

1. 3. Providing Personal Data and consenting to its processing are entirely voluntary. Any Personal Data shared with us is processed solely for the purposes and to the extent that the Website User has consented. However, if the Website User chooses not to provide the data required to fulfill the request and does not consent to its processing, it may not be possible to respond to the inquiry.

4. THE PURPOSE OF DATA PROCESSING

1. 1. The Personal Data sent and retrieved through the Website shall be processed in order to comply with legal obligation and also in accordance with applicable privacy laws, including the GDPR, and also to provide after-sales service for orders subject to our support services. Company does not process Personal Data sent or retrieved for purposes other than those permitted by law.

1. 2. The Company ensures that the processing of Personal Data is limited to the specific, explicit and legitimate purposes for those that were collected at source, and that will not be further processed in a manner incompatible with said purposes. Upon data collection, the Company informs Data Subjects in a simple and clear manner so that they can easily understand:

      • for the purpose of providing services electronically in the scope of providing Users with access to the content collected on the Website – then the legal basis for processing is the necessity of processing for the performance of the contract (Article 6(1)(b) GDPR);

      • for analytical and statistical purposes, in which case the legal basis for the processing is the legitimate interest of the Personal Data Controller (Article 6(1)(f) of the GDPR), consisting of conducting analyses of Users’ activities, as well as their preferences in order to improve the functionalities used and services provided;

      • for the purpose of possible establishment and investigation of claims or defense against claims – the legal basis for the processing is the legitimate interest of the administrator (Article 6(1)(f) GDPR), consisting in the protection of its rights;

      • for marketing purposes of the Personal Data Controller.

5. DATA RETENTION PERIOD

   1. The Data Controller may store and process personal Data sent or retrieved through the Website for as long as it is necessary to fulfil an order or agreement. Personal Data collected for the purposes of the Data Controller’s legitimate interests shall be retained as long as needed to fulfill such purposes.

   2. The Data Controller may be allowed to retain Personal Data for a longer period whenever the person whose data are processed has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

   3. The Website User shall be entitled to access the contents of their Personal Data and to request their rectification, to demand their complete deletion, to limit the right to process their personal data, and the right to object to their processing. The Website User shall be entitled to withdraw his/her consent at any time.

6. DATA SHARING AND TRANSFER OF DATA

1. 1. Personal Data Sharing with Third-Party Service Providers and its Purposes:

      • The Data Controller may share Personal Data with third-party service providers to support the website, products, and services subject to support services provided by the Company.

      • Examples of service providers: Data hosting, application development, marketing, sales support, customer support.

      • Reason for sharing: To provide information about products or services subject to our support services.

      • Specific examples: Removing repetitive information, analyzing data, providing marketing assistance, processing payments, supplementing information, improving products and services subject to support services, and providing customer service.

      • Restrictions on service providers: Prohibited from using Personal Data for purposes other than those specified and required to maintain confidentiality.

1. 2. Personal Data Sharing with Partners and its purposes:
      • Perform statistical analysis;
      • Provide sales support;
      • Provide customer support;
      • Improve partner programs and subscription services;

1. 3. The Personal Data Controller reserves the right to disclose selected information concerning the User to competent authorities or third parties who make a request for such information, relying on the relevant legal basis and in accordance with the provisions of the applicable law.
   4. The level of protection of Personal Data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, the Personal Data Controller transfers Personal Data outside the EEA only when necessary, and with an adequate degree of protection, primarily by:
      • cooperation with processors of Personal Data in countries for which a relevant decision of the European Commission has been issued regarding the determination of ensuring an adequate level of protection of Personal Data;
      • use of standard contractual clauses issued by the European Commission;
      • application of binding corporate rules approved by the relevant supervisory authority.
   5. The Personal Data Controller always informs about its intention to transfer Personal Data outside the EEA at the stage of collection.

7. DATA SECURITY

   1. We implement appropriate technical and organizational measures to ensure an adequate level of security with respect to the risks associated with the processing of personal data sent and retrieved through the Website, taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of the processing, in order to:

      • maintain the security and confidentiality of such data to which we have access, which are collected, used, stored or transmitted by the Data Controller;

      • protect such data from known or reasonably anticipated threats to their security and integrity, accidental loss, alteration, disclosure and any other unlawful forms of processing. The indicated measures include:

        1. ensuring proper data management through the implementation of a personal data protection policy and keeping records of processing activities and categories of processing activities;

        2. implementing a data access control system based on roles within the organization, on a need-to-know basis and raising awareness among the Data Controller’s employees;

        3. implementing procedures governing the handling of security incidents, including recording and monitoring the Data Controller’s systems;

        4. implementing technical measures such as network protection measures, creation of regular data backups, and encryption of transmitted and stationary data, including of the backups made. The Data Controller regularly monitors, reviews and updates the implemented technical and organizational measures.

1. 2. The Company guarantees that it complies with the duty of secrecy and confidentiality with regard to the personal data provided by the data subject via this Website.

8. WEBSITE USER RIGHTS

   1. As regards the processing of Personal Data covered by this Privacy Policy, the Data Subject shall have specific rights under applicable privacy legislation, including the GDPR.

   2. The User has the right to object to the processing of data for marketing purposes, if the processing is carried out in connection with the legitimate interest of the Personal Data Controller, as well as – for reasons related to the User’s particular situation – in other cases where the legal basis for data processing is the Personal Data Controller’s legitimate interest.

   3. Below are the most important rights together with their legal basis under General Data Protection Regulation you are entitled to:

      • right to information (Article 15 GDPR),
      • right to deletion (Article 17 GDPR),
      • right to correction (Article 16 GDPR),
      • right to restriction of processing (Article 18 GDPR),
      • right to data portability (Article 20 GDPR),
      • right to lodge a complaint with a supervisory authority (Article 77 GDPR),
      • right to withdraw consent (Article 7 (3) GDPR),
      • right to object to particular data processing measures (Article 21 GDPR).

   If you want to exercise your data protection rights you can contact us by sending an email to privacyteam@digitalassistance24.com.

9. COOKIES USE POLICY

   1. The Personal Data Controller uses cookies mainly to provide the User with services provided electronically. In this regard, the Personal Data Controller and other entities providing analytical and statistical services to the Personal Data Controller use cookies, storing information or accessing information already stored in the User’s telecommunications end device (computer, phone, tablet, etc.).

   2. Cookies mean binary data, most often small text files, saved and stored on the Website User’s devices, which are used in programming languages for more efficient communication between the website and the User.

   3. Cookies created on the User’s devices may originate from either the Data Controller’s system (so-called own Cookies) and external programs to monitor communication on the Internet (so-called external cookies coming from Google and other sites).

   4. The User has the ability to restrict or disable cookie access to their device. If this option is chosen, the User shall be able to use the Website, except for functions that by their nature require the use of cookies.

   5. Cookies can be divided into two types of files:

      • session cookies: they are stored on the User’s device and remain there until the end of the session of the particular browser. The recorded information is then permanently deleted from the device memory. The mechanism of session cookies does not allow collecting any personal data or any confidential information from the User’s device;
      • persistent cookies: they are stored on the User’s device and remain there until deleted. Ending a browser session or switching off the device does not remove persistent cookies from the User’s device. The mechanism of persistent cookies does not allow the collection of any personal data or any confidential information from the User’s device.

1. 6. Cookies do not collect any personal information, including names and email addresses.
   7. Each User can change their cookie settings in the browser they use, also by completely disabling the storage of cookies. If you do not disable the storage of cookies from various sites, this means that you agree to the recording and storing of Cookies on your computer.
   8. If the User chooses to reject all Cookies, they may not be able to use some of the content and services on our Website. However, disabling Cookies shall not prevent the User from browsing most websites.

10. CONTACT US

If you have a question regarding this Policy or the topic of data protection at our Company in general, you can contact us by sending an e-mail to privacyteam@digitalassistance24.com.

11. MODIFICATIONS

We reserve the right to update this Privacy Policy without prior notice. Any changes to our Privacy Policy shall become effective at the moment of posting the updated this Privacy Policy on our Website. If we modify this Privacy Policy, we will update the effective date at the bottom.

We recommend that you periodically review this Privacy Policy for any changes.

Last updated: October 18, 2024