Doshi App Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. Please also use the Glossary at the end of this privacy notice to understand the meaning of some of the terms used in this privacy notice.
1 IMPORTANT INFORMATION AND WHO WE ARE
1.1 Purpose of this privacy notice
1.1.1 This privacy notice aims to give you information on how we collect and process your personal data when you engage us to provide you with services, via your use of our ‘Doshi’ app or otherwise.
1.1.2 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
1.2.1 Doshi App Limited, a private limited company incorporated and registered in England and Wales with company number 13807674 whose registered address is at 36 Gloucester Place Mews, London W1U 8BA is the controller and is responsible for your personal data (collectively referred to as “we”, “us” and “our” in this privacy notice).
1.2.2 If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us by emailing us at: firstname.lastname@example.org.
1.2.3 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.3 Tell us about changes to your data
1.3.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.4 Third-party links
1.4.1 Our app may include links to third-party apps or websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party apps or websites and are not responsible for their privacy statements. When you leave our app, we encourage you to read the privacy notice of every third-party app or website you visit.
2 THE DATA WE COLLECT ABOUT YOU
2.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
2.2.1 Identity Data includes first name, last name, username or similar identifier, title and date of birth.
2.2.2 Contact Data includes your email address.
2.2.3 Technical Data includes the type of mobile device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use or your device’s time zone setting.
2.2.4 Transaction Data includes details about your crypto asset transactions that you submit via our crypto wallet software.
2.2.5 Profile Data includes services for which we have been engaged by you in the past, your interests, preferences, feedback and any survey responses.
2.2.6 Usage Data includes information about how you use our app and services.
2.2.7 Marketing and Communications Data includes your preferences in receiving in-app notifications, newsletters and marketing communications from us and our third parties and your communication preferences.
2.3 We may also collect, use and share Aggregated Data (such as statistical data) for any purpose. Aggregated Data may be gathered from your personal data but is not considered personal data in law as this data does not reveal your identity. For example, we may use your Usage Data (combined with that of other users of our app) to calculate the percentage of users accessing a specific feature on our app. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
2.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.5 If you fail to provide personal data
2.5.1 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with our services). In that case, we may have to stop providing services to you but we will let you know if that is the case at the time.
3 HOW IS YOUR PERSONAL DATA COLLECTED?
3.1 We use different methods to collect data from and about you including through:
3.1.1 Direct contact with you. You may give us your Identity Data, Contact Data, Profile Data, Marketing and Communications Data and Transaction Data by contacting us by email, filling in forms on our app or otherwise. This includes personal data you provide when you:
188.8.131.52 sign-up to be provided with any of the services we offer;
184.108.40.206 give us your contact details after clicking a referral link provided to you by one of our existing users;
220.127.116.11 give us information in order to allow us to provide you with our services or otherwise keep our promises in any contract we have with you;
18.104.22.168 subscribe to any publications or information on our app;
22.214.171.124 request marketing to be sent to you;
126.96.36.199 respond to any survey we provide to you; or
188.8.131.52 give us any feedback.
3.1.2 Automated technology. If you use our app, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
3.1.3 Third parties or publicly available sources. We may receive personal data about you from third parties (e.g. data providers such as Google) or publicly available sources.
4 HOW WE USE YOUR PERSONAL DATA
4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
4.1.1 Where we need to perform the contract we are about to enter into or have entered into with you.
4.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4.1.3 Where we need to comply with a legal or regulatory obligation.
4.2 Purposes for which we will use your personal data
4.2.1 We have set out below a description of all the ways we plan to use your personal data, and the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
4.2.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us via the means set out in paragraph 1.2.2 above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity: To register you as a new user
Type of data: (a) Identity Data (b) Contact Data
Lawful basis for processing (including basis of legitimate interest): (a) Performance of a contract with you
Purpose/Activity: To provide you with our services, including providing you with in-app notifications
Type of data: (a) Identity Data (b) Contact Data (c) Transaction Data
Lawful basis for processing (including basis of legitimate interest): (a) Performance of a contract with you (b) Necessary for our legitimate interests (in order to provide you with our services)
Purpose/Activity: To manage our relationship with you including: (a) notifying you about proposed changes to this privacy notice or our other terms and conditions; and (b) any changes to our app
Type of data: (a) Identity Data (b) Contact Data (c) Marketing and Communications Data(d) Profile Data
Lawful basis for processing (including basis of legitimate interest): (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (to inform you of any changes to our terms and conditions) (c) Necessary for our legitimate interests (to keep our records updated, to understand how our users use our services and to develop our services and grow our business)
Purpose/Activity: To provide you with rewards and prizes arising from your use of our services or after you have successfully referred our services to a friend via our referral program.
Type of data: (a) Identity Data (b) Contact Data (c) Marketing and Communications Data (d) Profile Data (e) Technical Data
Lawful basis for processing (including basis of legitimate interest): a) Performance of a contract with you (c) Necessary for our legitimate interests (to understand how our users use our services and to develop our services and grow our business)
Purpose/Activity: To run and protect our business, including our app (including finding and resolving problem, analysing data, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data
Lawful basis for processing (including basis of legitimate interest): (a) Necessary for our legitimate interests (for running our business, providing IT services, network security, to prevent fraud and where we are reorganising how our business is structured) (b) Necessary to comply with a legal obligation
Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you (including those of third parties)
Type of data: (a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data (e) Profile Data (f) Financial Data (g) Marketing and Communications Data
Lawful basis for processing (including basis of legitimate interest): (a) Necessary for our legitimate interests (to develop our services and grow our business) (b) You have provided your explicit consent
4.3.1 We aim to provide you with choices regarding certain uses of your personal data, particularly around marketing and advertising.
4.4 Promotional offers from us
4.4.1 We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on products or services that we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
4.4.2 You will receive marketing communications from us if you have asked us for information on a service we provide or have signed-up to receive one of our services and, in each case, you have not told us that do not receive that marketing.
4.5 Third-party marketing
4.5.1 We will get your permission before we share your personal data with any other company for marketing purposes.
4.6 How to stop receiving marketing messages from us
4.6.1 You can ask us, or third parties, to stop sending you marketing messages at any time by following the ‘opt-out’ links on any marketing message sent to you or by contacting us via the means set out in paragraph 1.2.2 above.
4.7 Change of purpose
4.7.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is related to the original purpose. If you wish to get an explanation as to how the processing for the new purpose is related to the original purpose, please contact us via the means set out in paragraph 1.2.2 above.
4.7.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
4.7.3 Please note that we may process your personal data without your knowledge or permission, in compliance with the above rules, where this is required or permitted by law.
5 PROVIDING YOUR PERSONAL DATA TO OTHERS
5.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.2.2 above.
5.1.1 Internal Third Parties’ as set out in the glossary to this privacy notice.
5.1.2 ‘External Third Parties’ as set out in the glossary to this privacy notice.
5.1.3 If we choose to sell, transfer, or merge parts of our business or our assets, the new owners of our business or those assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
5.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6 INTERNATIONAL TRANSFERS
6.1 Whenever we transfer your personal data outside the UK, we make sure that it is protected in the same as in the UK by using at least one of the following safeguards:
6.1.1 Transferring your personal data to a country that is considered by UK data protection laws to provide an adequate level of protection for personal data.
6.1.2 Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
7 DATA SECURITY
7.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to access it. They will only process your personal data on our instructions and they must keep it secret.
7.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8 DATA RETENTION
8.1 How long will you use my personal data for?
8.1.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
8.1.2 To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8.1.3 Details of retention periods for different aspects of your personal data can be obtained by contacting us via the means set out in paragraph 1.2.2 above.
8.1.4 In some circumstances you can ask us to delete your data: see Request erasure below for further information.
8.1.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9 YOUR LEGAL RIGHTS
9.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below:9.1.1 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
9.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to check the accuracy of the new data you provide to us.
9.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
9.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your rights. You also have the right to object where we are processing your personal data in order to provide you with details of products, services and offers which may be relevant for you. In some cases, we may demonstrate that we have a right to process your information which override your rights.
9.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
184.108.40.206 If you want us to establish the data's accuracy.
220.127.116.11 Where our use of the data is unlawful but you do not want us to erase it.
18.104.22.168 Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
22.214.171.124 You have objected to our use of your data but we need to check whether we have any fair grounds to continue using it.
9.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a commonly used format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
9.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
9.2. If you wish to exercise any of the rights set out above, please contact us via the means set out in paragraph 1.2.2 above.
9.3 No fee usually required
9.3.1 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unreasonable, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
9.4 What we may need from you
9.4.1 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
9.5 Time limit to respond
9.5.1 We try to respond to all properly made requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will let you know and keep you updated.
10.1 Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
10.2 Internal Third Parties means other companies in our corporate group who you may need to provide you with services.
10.3 External Third Parties means:
10.3.1 Service providers acting as data processors who provide us with IT and system administration services, such as the organisations which: (i) help us to check the identity of users of our app; and (ii) help us to provide access to your cryptoassets via our app by using the email account linked to your social media login used to access the app.
10.3.2 Professional advisers including bankers, solicitors, auditors and insurers who provide us with banking, legal, insurance and accounting services.
10.3.3 HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
10.4 Legitimate interest means the interest of our business in conducting and managing our business to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us via the means set out in paragraph 1.2.2 above.
10.5 Performance of a contract means processing your data where it is necessary for us to keep our promises under any contract we have with you or to take steps at your request before entering into such a contract.