Last updated: 17-05-2018
Dooga Ltd, a company registered in the United Kingdom at 6, Agar Street, London WC2N 4HN, United Kingdom (“Cubits”) is the Controller of Data under the terms of the Data Protection Act (1998) and Regulation (EU) 2016/679.
Should you have any queries, concerns, requests or complaints in relation to the manner in which we process your personal data, you may contact our Data Protection Officer by email on [email protected]. You also have the right to lodge a complaint before the Information Commissioner Office (ico.org.uk) with regard to matters concerning your personal data.
We may collect and process personal data provided directly by you; we also process, insofar as necessary, personal data provided to us by third parties, including publicly accessible data, personal data legitimately provided by other group companies and personal data provided by other trusted third parties. You are responsible to provide us with personal data that is correct and inform us of any changes occurring in your data in writing, in order that we may take all reasonable measures to keep our records in your regard correct and up to date.
You shall have the right to object to any of the above-mentioned legitimate company interests as a basis for the processing of personal data by contacting our Data Protection Officer by email on [email protected]. If you submit an objection, we will no longer process your personal data unless we can give evidence of mandatory, legitimate reasons for processing, which outweigh your interests, rights, and freedoms, or processing serves the enforcement, exercise, or defence of interests.
In the event that you have provided us with specific consent:
If you do not want us to use your data in this way, or to pass your details on to specific third parties for marketing purposes, you have to the right to withdraw your consent at any time in the Privacy section on your profile Settings page and we will update our records. Withdrawal of consent does not affect the legality of data processed prior to withdrawal.
We may disclose your personal data to third parties for the purpose of fulfilling legitimate company interests:
We will ensure that all companies to which we disclose your Personal Data will only process it in accordance with our instructions and on our behalf, and may only use such data to the extent to which we ourselves are entitled. All such companies and third parties will further be required by us to meet the requirements of data protection legislation and Cubits’ strict privacy and retention policies to keep your data secure at all times.
We may, if necessary or authorised by law, provide customer data to law enforcement agencies, regulatory organisations, courts or other public authorities. We attempt to notify our customers about legal demands for their Personal Data unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe that the requests are disproportionate, vague or lack proper authority, but we do not promise to challenge every demand.
Your personal data shall not be processed for purposes other than those it was collected for; should further processing be required, you will be informed of that purpose and provided with all necessary information.
In the event that you have provided us with consent, we may share your personal data with any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 and namely StrongKeep, CubitsPay and CubitsTrade.
In the event you have provided us with consent, we may share your personal data with selected third parties including:
You shall have the right to object to any of the above-mentioned legitimate company interests as a basis for the processing of personal data and to forward any queries you may have by contacting our Data Protection Officer by email on [email protected] If you submit an objection, we will no longer process your personal data unless we can give evidence of mandatory, legitimate reasons for processing, which outweigh your interests, rights, and freedoms, or processing serves the enforcement, exercise, or defence of interests.
All personal data you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.
In line with applicable law, we shall, where lawfully obliged, notify the competent authorities and/or you in cases of personal data breach and will keep a log of any such breaches.
We will process and store your personal data for as long as it is necessary in order to fulfill our contractual, regulatory and statutory obligations. We will assess and respond to requests to delete data. We will delete data provided that the data is no longer required in order to fulfill contractual, regulatory or statutory obligations, or the fulfillment of any obligations to preserve records according to law.
We will normally retain your records for a minimum of five years to comply with legal, regulatory and contractual requirements unless there is a particular reason to hold the records for longer; your personal data may be retained for longer periods in the event of prospective or pending debt collecting, legal or law-enforcement proceedings and until such proceedings are formally and definitively concluded.
In relation to your personal data, you have the right to:
You shall also have the right to ask us not to process your personal data for marketing purposes. We will seek your explicit consent (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also withdraw your consent in the Privacy section on your profile Settings pageby contacting us. You also have the right to lodge a complaint before the Information Commissioner Office (ico.org.uk) with regard to matters concerning your personal data.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
You have the right to request, free of charge, access to and a copy of your personal data as processed by us.
In establishing and carrying out our business relationship, we generally do not make use of fully automated decision making. If we use this procedure in individual cases, we shall inform you of this separately, provided it is a legal requirement.