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1.1. We are Zaya Solutions Limited located 10/F., Guangdong Investment Tower, 148 Connaught Road Central, Hong Kong.
1.2. This Privacy Policy sets out how we collect and use your personal information when you visit our sites https://www-donationalerts-com.da.ezzha.ru/ and https://dalink.to (“Sites”), use our mobile application “Donation Alerts Studio” or our online service “DonationAlerts” (collectively, “DA Services”) offered by Zaya Solutions Limited at https://www-donationalerts-com.da.ezzha.ru/ and the choices available to you in connection with our use of your personal information (“Privacy Policy”).
The Sites and DA Services are hereinafter collectively referred to as the “DA Platform”. This Privacy Policy should be read alongside, and in addition to, our terms and conditions at https://www-donationalerts-com.da.ezzha.ru/terms-of-service/broadcasters (“Terms”), Donation Alerts End User License Agreement for DA Studio available at https://studio-donationalerts-com.da.ezzha.ru/eula (“EULA”) and our Cookie Policy (available at https://www-donationalerts-com.da.ezzha.ru/cookie-policy).
In case of any contradictions between this Privacy Policy and the Terms or EULA, this Privacy Policy will prevail.
2.1. By making available the DA Platform we, acting reasonably and in
good faith, believe that you:
(a) have all necessary rights to
register and use the DA Platform;
(b) provide true information about
yourself to the extent necessary for use of the DA Platform;
(c)
understand that by the posting your personal information you have
manifestly made this information public, and this information may become
available to other DA Platform users and internet users, be copied and
disseminated by them;
(d) understand that some types of information
transferred by you to other DA Platform users cannot be deleted by you
or us;
(e) are aware of and accept this Privacy Policy.
2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.
3.1. In order to implement the agreement between you and us, and provide you with access to the use of the DA Platform, we will improve, develop and implement new features to the DA Platform, and enhance the available DA Platform functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data. We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.
3.2. We set out in more detail the information we may collect when you use the DA Platform, why we collect and process it and the legal bases below.
|
Information Collected |
Purpose |
Legal Basis |
|
|
1 |
Data you provide for registering in DA Platform: data obtained via third parties in case you log in through a third-party social network or authentication service (such as Facebook, Google, YouTube, among others), including your social network nickname and email, your nickname that you create at the process of registering |
We use this information in order to manage and administer DA Platform provided to you. We use this data to enable us to fulfill our obligations to you as part of DA Platform (e.g. in cases where you request restoration of your account). See section 8.3 of this Privacy Policy for more information. |
Legitimate interests |
|
2 |
Additional data you provide when you edit your profile page at https://www-donationalerts-com.da.ezzha.ru/or on dedicated service profile page via including your name, surname, mobile phone, email, nickname, country. |
We use this information in order to provide DA Platform to
you, to manage and administer DA Platform and as additional
information to verify your account to prevent abuse and
infringements of your or other persons' rights. |
Legitimate interests |
|
3 |
Additional data received when you access DA Platform, including information regarding technical interaction with DA Platform such as your IP-address, time of registration on DA Platform, time of your last visit of DA Platform, device ids, country and language settings. |
We use your data for internal review in order to constantly improve the content of DA Platform and web pages, optimizing your user experience, to understand any errors you may encounter when using DA Platform, to notify you of changes to DA Platform and to personalise the use of our DA Platform. |
Legitimate Interests |
|
4 |
Information that is automatically received at the time of access to DA Platform with the use of cookies. |
Please see our cookies policy, which sets out the types of cookies we use and what we use these cookies for. |
Consent |
|
5 |
Information that is created by you while using DA Platform (including User Content). This information can be available to all viewers of the Broadcaster Content where the User Content is placed |
We use this information in order to manage and administer DA Platform including providing our DA Platform to you. |
Legitimate interests |
|
6 |
Information that is created by you while placing requests to our Services support. |
We use this information in order to verify your identity and
to fullfil your support request. |
Legitimate interests |
|
7 |
Information that is received as the result of your using payment functionality on the Sites (e.g. your first name, last name and patronymic (if necessary), first and last four digits of your card number that are needed for the option of matching these details with user’s id number). |
We use this information in order to manage and administer the Sites including providing our DA Services to you. |
Legitimate interests |
|
8 |
Data collected via third parties, in case you choose to provide such data from a third-party social network or authentication service (such as Facebook, Google, YouTube, among others), when you log in using such network and/or service or connect such network and/or service to our DA Platform, including your social network ids (such as Google ID), application store ids, nickname, email and friends list, subscribers list, streams list, channel name, channel description, channel URL, avatar or profile picture, stream key. |
We use this information in order to manage and administer the DA Platform provided to you. |
Legitimate interests |
|
9 |
Where necessary, data collected via third parties, in case you choose to provide such data from third party providers of “know your customer” and anti-money laundering verification services, including, your full name, date of birth, citizenship, a copy of your identity or another document containing your first name, surname, photograph, number of your principal identity document, registration address, description of your activity. |
We may use this data in order to verify your account, prevent abuse and infringement of your or other persons’ rights, and comply with anti-money laundering and “know your customer” legal obligations. |
Processing is necessary for compliance with a legal obligation |
|
10 |
Data you provide while using DALink: social network IDs, social network nickname, links to your pages on Third-Party Services. |
We use this information in order to provide DALink to you. |
Performance of our contract with you |
3.3. In case you are using our mobile application “DonationAlerts Studio”, the points below apply in addition to those described above:
|
Information Collected |
Purpose |
Legal Basis |
|
|
11 |
Data obtained via third parties, including your social network IDs, application store IDs, social network nickname, broadcasting information (such as statistic data about viewers of your broadcasts), when you connect your social account (e.g. Facebook, Google) to the DA Platform. |
We import this information into your profile. We use this information in order to manage and administer the DA Platform provided to you. |
Legitimate interests |
|
12 |
Additional data received when you access the DA Platform, including information regarding technical devices, technical interaction with the DA Platform, such as your IP-address, time of registration in the DA Platform, time of authorization in the DA Platform, device IDs, country and language settings, device model and operating system used, device graphics memory information, your installed apps, type of browser, your Internet provider and/or phone network operator, network type, screen resolution, or RAM size. |
We use your data for internal review in order to constantly improve the content of our DA Platform and web pages, to optimise your user experience, to understand any errors you may encounter when using the DA Platform, to notify you of changes to the DA Platform, and to personalise the use of our DA Platform. |
Legitimate
interests |
3.4. Our legitimate interests include (1) maintaining and administrating DA Platform; (2) providing DA Platform to you; (3) improving the content of DA Platform and web pages; (4) processing of the data that was manifestly made public by you (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law.
3.5. Your personal information may also be processed if it is required by
a law enforcement or regulatory authority, body or agency or in the
defence or exercise of legal claims.
We will not delete personal
information if it is relevant to an investigation or a dispute. It will
continue to be stored until those issues are fully resolved and/or
during the term that is required and/or permissible under
applicable/relevant law.
3.6. You may withdraw your consent for sending you marketing information by amending your privacy settings of your account. An option to unsubscribe will also be included in every email sent to you by us or our selected third party partners.
3.7. Please note, if you do not want us to process sensitive and special
categories of data about you (including data relating to your health,
racial or ethnic origin, political opinion, religious or philosophical
beliefs, sex life, and your sexual orientation) you should take care not
to post this information or share this data on DA Platform.
Once you
have provided this data it will be accessible by the users of the
web-sites (including mobile versions) where this data is posted and it
becomes difficult for us to remove this data.
3.8. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer DA Platform, you may not be able to access and use DA Platform.
3.9. If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.
4.1. Your nickname can be available to all viewers of your Broadcasting Content in the Internet when you use DA Platform. We take technical and organizational measures to ensure that your data is safe. Please note that by the posting your personal information you have manifestly made this information public, and this may become available to other Service users and internet users and be copied and/ or disseminated by such users. Once this data is transferred by you to other users you will not be able to delete this data.
4.2. We may share your data with our affiliates. Sometimes we may also need to share your data with a third party in order to provide DA Platform to you or to administer DA Platform, for example if you choose to share your data across other social media platforms.
4.3. Zaya Solutions Limited and our other affiliated entities or our selected third party partners with our permission, using their own ad servers, can show advertisements to you.
4.4. We may transfer your data to state or local authorities to which we are required to provide information in accordance with applicable law upon a corresponding request.
4.5. Sharing in the general conduct of business. We may also share your data with our affiliates and keep some of your personal information in our business records for the accounting and compliance purposes. As such, you hereby consent that we may also transfer your personal information to a third party if we decide to transfer or sale of all or substantially all of our business to which this Privacy Policy relates to, whether by merger, sale of stock, sale of assets, or otherwise, if permitted by and done in accordance with applicable law, so you can continue to receive service and information in connection with that business with as little disruption as possible. Similarly, you hereby consent that in that case your personal data will be processed by our successor or assignee in accordance with this Privacy Policy.
4.6. We may transfer your data to banks, licensed payment partners, and other parties involved in providing DA Platform to you if we receive a reasoned legal request from them. A reasoned legal request shall be defined as a request, executed in accordance with applicable law, that specifies the legal basis for obtaining personal data and the purpose for which it is requested, including compliance with "know your customer", fraud prevention, and regulatory requirements. Such transfer is carried out to the extent necessary to achieve the stated purposes, taking into account the principle of data minimization.
5.1. DA Platform may contain links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party DA Platform and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.
5.2. In case you intend to connect your YouTube or Google account to the DA Platform using YouTube API Services, you may review and, if necessary, adjust your YouTube privacy settings at Google security settings page at https://security.google.com/settings/security/permissions before linking or connecting them to our Sites or DA Services. You can find more information on YouTube and Google’s privacy at https://policies.google.com/ and Google Privacy Policy at Google Privacy Policy at http://www.google.com/policies/privacy.
5.3. We bear no liability for the actions of third parties which, as the result of your use of the internet or the DA Platform, obtain access to your information in accordance with the confidentiality level selected by you.
5.4. We bear no liability for the consequences of use of the information which, due to DA Platform nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted in DA Platform.
6.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in CIS.
6.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.
7.2. You may delete your personal data by removing the data from your account or by sending us an email to support@donationalerts-com.da.ezzha.ru.
7.3. We may remove your account, or the information you post as provided by the Terms.
8.1. You have the following rights, in certain circumstances, in relation to your personal information:
(a) Right to access your personal information.
(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
(c) Right to restrict the use of your personal information.
(d) Right to request that your personal information is erased if:
- it is no longer required in relation to the purposes for which it was gathered or processed in another way;
- you withdraw your consent concerning processing subject to consent;
- you are justifiably opposed to the processing;
- it has been subject to illicit processing; or
- it is imposed by law.
(e) Right to object to processing of your personal information.
(f) Right to data portability (in certain specific circumstances).
(g) Right not to be subject to an automated decision.
(h) Right to lodge a complaint with a supervisory authority.
(i) For processing based upon your consent, the right withdraw that consent at any time.
(j) You may have other rights under your legislation of your country of residence, including right to define the instructions relative to the outcome of your personal data after your death.
8.2. You also have a right to independently remove personal information on your account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you. If you reside in France you have the right to register on the list of opposition to telephone canvassing on www.bloctel.fr.
8.3. If you would like to exercise these rights, please contact Support Service at support@donationalerts-com.da.ezzha.ru or send your request to us, in writing to 10/F., Guangdong Investment Tower, 148 Connaught Road Central, Hong Kong. We will aim to respond to you within period established by applicable law. We will need to verify your identity before we are able to disclose any personal data to you.
8.4. In case you provided the access of the DA Platform to your YouTube account (for example if you registered on the DA Platform using YouTube social network account) you can revoke that the access of the DA Platform to your YouTube account via the Google security settings page at https://security.google.com/settings/security/permissions.
9.1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
9.2. Access to DA Platform is authorized using by the relevant social network your login (e-mail address or mobile phone number) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.
10.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.
11.1. If you have any questions, please send your inquiries to Service support at support@donationalerts-com.da.ezzha.ru or in writing to 10/F., Guangdong Investment Tower, 148 Connaught Road Central, Hong Kong. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within period established by applicable law.
11.2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
11.3. The e-mail address of our DPO is dpo@donationalerts-com.da.ezzha.ru.
Only the English version of this document has legal effect. Any translations of this document to other languages are provided for your convenience only.
