Privacy and cookies policy
Dear User
If you have arrived here, it is a reliable sign that you value your privacy. We understand this very well, so we are putting in your hands a document, in which you will find in one place the rules for processing personal data and the use of cookies and other tracking technologies.
We process your personal data primarily for purposes related to your use of our website, such as maintaining your user account, placing orders and handling contracts, processing complaints and withdrawals, fulfilling legal tax obligations, sending newsletters, claims cases, etc. We process your personal data for the period of time necessary to fulfill the particular purpose. You have the right to access, rectify, erase or restrict processing of your personal data, object to processing, as well as the right to data portability. In addition, you may file a complaint with the competent authority for data protection.
For detailed information on the principles of processing your personal data, please see the following Privacy Policy.
- WHO IS THE CONTROLLER OF PERSONAL DATA
- WHO CAN YOU CONTACT REGARDING THE PROCESSING OF PERSONAL DATA?
- FOR WHAT PURPOSES DO WE PROCESS PERSONAL DATA?
- WHAT INFORMATION DO WE HAVE ON YOU?
- WHERE DO WE GET YOUR PERSONAL INFORMATION FROM?
- WHETHER THE DATA IS SAFE
- HOW LONG WILL WE KEEP PERSONAL INFORMATION?
- WHO ARE THE RECIPIENTS OF PERSONAL DATA?
- DO WE TRANSFER DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANIZATIONS?
- WHAT ARE YOUR RIGHTS?
- IS THERE ANYTHING ELSE YOU SHOULD KNOW ABOUT?
- IS THIS PRIVACY POLICY SUBJECT TO CHANGE?
- COOKIES POLICY
If you have any concerns about the Privacy Policy, you can contact us at any time by sending a message to dribbledata@gmail.com.
1: Who is the controller of personal data?
The administrator of your personal data is VALORPICKS LTD 27 Old Gloucester Street, London, WC1N, 3AX, United Kingdom, Company number: 15408665. This Privacy Policy applies to the platform under the name "dribbledata", which belongs to the administrator.
With regard to social media profiles related to our website, according to the case law of the Court of Justice of the European Union, the social network provider is a joint controller of personal data together with the controller of the respective profile. Details on the processing of personal data by individual social media providers can be found here:
2: Who can you contact regarding the processing of personal data?
As part of the implementation of a data protection system in our organization, we decided not to appoint a data protection officer due to the fact that it is not mandatory in our situation.
For matters related to data protection and privacy in the broadest sense, you can contact us at dribbledata@gmail.com. In terms of social media, you can additionally contact directly the administrators of the social networks where we maintain our profiles.
3: For what purposes do we process personal data?
These targets are more than one. Below is a list of them, along with a more detailed discussion. We have also assigned to each purpose the corresponding legal basis for processing:
User account maintenance:
When you create a user account, you must provide the data necessary to create an account specified in the registration form. Providing data is a condition for creating an account.
As part of editing your account details, you can enter your further details, according to the available options within your account.
The data is processed for the purpose of providing the user account service to you. After deletion of the user account, the data goes into an archive for the possible establishment, investigation or defense of claims related to the user account service.
Legal basis: Article 6(1)(b) of the GDPR
Order processing and contract handling:
When placing an order, you must provide the data necessary for its execution specified in the order form. Providing data is a condition for placing an order.
Each order is recorded in a database, which means that your personal data assigned to the order is also accompanied by order information such as the date and time of the order, the order ID number, the subject of the order, the price, the method and date of payment, the date and time of download (in the case of digital content).
In connection with the conclusion of a contract, it may also process your other personal data in order to perform the services provided for in the contract that has been concluded. The scope of this data depends on which personal data is needed to perform the contract.
The data is processed for the purpose of entering into and performing the contract. Once the contract has been executed, the data goes into the archive for the purpose of possibly establishing, asserting or defending claims related to the contract. Data also goes into accounting records for the purpose of meeting tax obligations.
Legal basis: Article 6(1)(b) GDPR, Article 6(1)(f) GDPR
Handling complaints or withdrawals:
If you make a complaint or withdraw from the contract, you will provide personal information contained in the body of the complaint or statement of withdrawal. Provision of data is a condition for submitting a statement of withdrawal or complaint.
The data is processed for the purpose of handling the withdrawal or complaint process. Once such a process has been carried out, the data goes into an archive for the purpose of possibly establishing, asserting or defending claims related to the handling of the withdrawal process or the complaint process. Data also goes into accounting records for the purpose of meeting tax obligations.
Legal basis: Article 6(1)(c) of the GDPR in connection with the relevant provisions on the right of withdrawal and liability for compliance with the contract, Article 6(1)(b) of the GDPR
Newsletter handling/email notification system:
When signing up for the newsletter, you must provide the data necessary to receive it as specified in the subscription form. Providing data is a condition for receiving the newsletter.
In addition, the mailing system records your IP number you used when signing up for the newsletter, determines your approximate location, the mail client you use for email, and tracks your actions taken in connection with messages sent to you. As such, we also have information about which messages you opened, within which messages you clicked on links, etc.
In the mailing system, we may also define, based on various criteria related to your activity, interests or other preferences, specific groups or segments of newsletter recipients that influence what kind of messages you receive in the newsletter.
The data provided by you in connection with subscribing to the newsletter is used for the purpose of sending you the newsletter, and the legal basis for its processing is the performance of the contract for the provision of electronic services, as well as our legitimate interest, which in this case is the fulfillment of marketing purposes.
Regarding the processing of information that does not come from you, but is collected automatically by the mailing system, we rely in this respect on our legitimate interest to analyze the behavior of newsletter subscribers in order to optimize mailing activities.
You can unsubscribe from the newsletter at any time by clicking on the dedicated link included in each message sent as part of the newsletter, or by simply contacting us.
Legal basis: Article 6(1)(b) GDPR Article 6(1)(f) GDPR
Contact and correspondence handling:
When you contact us through available means of communication, such as e-mail, social messaging, chat rooms, etc., you naturally provide your personal information contained in the content of your correspondence. Provision of data is a condition for making contact.
A communication system (e.g. chat, instant messaging) may be operated by an external provider. In such a situation, the use of the system is subject to the terms and conditions and privacy policy of the external provider.
Data is processed for the purpose of conducting communications, which is our legitimate interest. Once the communication has been completed, the data goes into an archive for the possible establishment, investigation or defense of claims related to the communication.
Legal basis: Article 6(1)(f) GDPR
Implementation of tax and accounting obligations:
In connection with the performance of the contract, we also carry out various tax and accounting obligations, particularly in the form of issuing an invoice, incorporating the invoice into our accounting records, keeping records, etc.
In order to issue an invoice, we process such data as name, company, business address, TIN, among others.
Provision of data required by tax law is necessary for the fulfillment of the obligations indicated.
Legal basis: Article 6(1)(c) of the GDPR in connection with the relevant provisions of tax law
Creating an archive:
For the purposes of our business, we may create archives: both in traditional and digital form. The archives include personal data that we have processed in connection with you, and the scope of the archives may vary depending on what data has come to us and the scope of the data justified in terms of archiving. In this case, we rely on our legitimate interest in organizing and arranging personal data carriers.
Legal basis: Article 6(1)(f) GDPR
Defense, establishment or enforcement of claims:
The use of our website, as well as the conclusion of a contract with us, may give rise to certain claims in the future on our side or yours. Accordingly, we are entitled to process personal data for the purpose of defending, establishing or asserting claims. For this purpose, we may process any personal data that is related to the claim in question, so the scope may vary depending on what the claim is about. In this case, we rely on our legitimate interest to protect our interests in this regard.
Legal basis: Article 6(1)(f) GDPR
Social media handling:
If you follow our profiles on social networks or interact with content we publish on social media, we naturally see your data, which is publicly available in your social profile. We process this data only within the respective social network and only for the purpose of operating the respective social network, which is our legitimate interest.
If you contact us via private message, you naturally provide us with your personal data contained in the body of the correspondence, in particular your image and name. Your data is processed in this case for the purpose of contacting you, and the basis for processing is our legitimate interest.
It may be that we are the party initiating contact with you via social media to offer cooperation, in which case your data will be processed for the purpose of searching for potential contractors, offering and establishing cooperation, which is our legitimate interest.
Messages sent to us via social media are subject to automatic archiving through tools available within each social network and are available to us until you delete them. You have access to all messages exchanged with us in the private messages tab.
Your use of social networking sites is subject to the rules and privacy policies of the administrators of these sites, and these administrators provide electronic services to you, fully independently and autonomously of us.
Legal basis: Article 6(1)(f) GDPR
Implementation of obligations related to the protection of personal data:
As a data controller, we are obligated to fulfill our data protection obligations. Accordingly, we may process your personal data insofar as it is necessary to fulfill these obligations (e.g., when processing your request for your personal data). The extent of the data depends on what data we need to perform the obligation and prove compliance with the GDPR. In addition, in this case we also rely on our legitimate interest in securing the data necessary to demonstrate accountability.
Legal basis: Article 6(1)(c) GDPR, Article 6(1)(f) GDPR.
4: What information do we have about you?
We have described the scope of data processing for each processing purpose. Information in this regard can be found above, in Section 3 of the Privacy Policy. Among the data are information such as:
- name,
- country of origin,
- email address,
- telegram nickname,
- phone number,
- IP address,
- address for delivery,
- invoice details,
- bank account number,
- details of the order placed,
- data collected in the mailing system,
- information visible in social media profiles,
- information contained in the correspondence.
5: Where do we get your personal information from?
In most cases, you provide them to us yourself. For example, this happens when you register a user account, place an order, send a complaint or withdraw from a contract, contact us via email or chat, or use features available on our Site or external services (e.g., social media).
6: Is the data safe?
We care about the security of your personal data. We have analyzed the risks involved in the various processes of processing your data, and then implement appropriate security and personal data protection measures. We constantly monitor the state of the technical infrastructure, train our staff, look at the procedures in place, and make the necessary improvements.
7: How long will we keep personal information?
We process your personal data for as long as it is reasonable within the framework of a given purpose for processing your personal data, and therefore the processing periods vary depending on the purpose. Please note that the termination of the processing of your data for one purpose does not necessarily lead to the complete deletion or destruction of your personal data, as the same set of data may be processed for another purpose for the period indicated for it. Complete deletion or destruction of data occurs when we have completed all purposes and in other cases indicated in the GDPR.
Below you will find a description of the processing periods:
- User account - data related to the user account is processed for the duration of the user account;
- Fulfillment of orders and the concluded contract - data related to the contract are processed for the time necessary to conclude and perform the contract;
- Complaints and withdrawals - data related to complaints and withdrawals are processed for the time necessary to handle the complaint or withdrawal;
- Newsletter - data related to the newsletter will be processed for the duration of your use of the newsletter;
- Contact and correspondence handling - data related to correspondence handling will be processed for the duration of contact between us;
- Tax and accounting obligations - data related to the performance of tax and accounting obligations will be processed for the time prescribed by tax law, usually 5 years after the end of the fiscal year;
- Archive - data related to the archive will be processed until the information that is in the archive is no longer useful;
- Determination, investigation and defense of claims - data related to claims will be processed until the statute of limitations for claims, whereby the period of limitation for claims may vary in light of applicable laws (e.g. for businesses it may be 3 years, and for consumers 6 years);
- Social media - in general, we have no control over the retention period of your personal data on social media. They are available on Facebook or Twitter under the terms of the rules and privacy policies of those sites. We are not able to remove your data from Facebook or Twitter - only you can do that;
- Data Protection Obligations - Data related to the protection of personal data will be processed until it becomes obsolete, you successfully lodge an objection, or the expiration of the statute of limitations on our liability as a data controller.
Where we process your personal data on the basis of consent you have given us, you may withdraw such consent at any time: either by your action or by contacting us at the contact details provided. Remember that withdrawal of consent does not affect the lawfulness of the processing that was carried out on the basis of consent before its withdrawal.
8: Who are the recipients of personal data?
We would venture to say that modern business cannot do without services provided by third parties. We also use such services. Some of these services involve the processing of your personal data. Third-party service providers that are involved in the processing of your personal data are:
- Hosting provider - for the purpose of storing data on the server;
- Mailing system/email notification system provider - for the use of the mailing/email notification system;
- Invoicing system provider - for the purpose of invoicing;
- Cloud provider - for the use of cloud solutions;
- Accounting office - for the use of accounting services;
- Law firm - for the purpose of providing legal services to us;
- Maintenance - for the purpose of conducting technical work on those areas where data is processed;
- Other subcontractors, in particular IT solution providers - for the purpose of working with various subcontractors who may have access to your personal data if they provide services in connection with such access.
If the need arises, your data may be shared with a legal advisor or attorney bound by professional secrecy. The need may arise from the need for legal assistance requiring access to your personal information.
Your personal data may also be transferred to the tax authorities to the extent necessary for the fulfillment of tax and accounting obligations. This includes, in particular, all declarations, reports, statements and other accounting documents containing your personal data.
In addition, if necessary, your personal data may be shared with entities, authorities or institutions entitled to access the data under the law, such as police, security services, courts, prosecutors.
9: Do we transfer data to third countries or international organizations?
Yes, part of the processing operations of your personal data may involve their transfer to third countries. We transfer your personal data to third countries in connection with the use of tools using resources located in third countries, in particular in the United States. The providers of these tools guarantee an adequate level of personal data protection through the relevant compliance mechanisms provided by the GDPR, in particular through the use of standard contractual clauses.
Currently, your personal data is transferred to third countries in connection with our use of the following solutions:
- Email | Provider: Google | Country: USA;
- Email notifications | Provider: Resend| Country: USA;
- Hosting| Provider: Netlify| Country: USA;
- Database| Provider: Neon| Country: USA;
10: What are your rights?
The GDPR grants you the following potential rights related to the processing of your personal data:
- The right to access your data and receive a copy of it;
- The right to rectify (amend) your data;
- The right to erasure (if, in your opinion, there is no basis for us to process your data, you can request that we erase it);
- The right to restrict data processing (you can request that we restrict the processing of your data only to storing it or performing activities agreed with you, if in your opinion we have incorrect data or are processing it unduly);
- The right to object to processing (you have the right to object to processing on the basis of a legitimate interest; you should indicate the particular situation that you think justifies us stopping the processing covered by the objection; we will stop processing your data for these purposes unless we demonstrate that the grounds for our processing override your rights or that your data are necessary for us to establish, assert or defend claims);
- The right to data portability (you have the right to receive from us in a structured, commonly used machine-readable format the personal data you have provided to us under a contract or your consent; you can have us send this data directly to another entity);
- The right to withdraw consent to the processing of personal data, if you have previously given such consent;
- The right to lodge a complaint with a supervisory authority (if you find that we are processing your data unlawfully, you can file a complaint about it with the authority competent for personal data protection).
The rules related to the exercise of the rights indicated above are described in detail in Articles 16-21 of the GDPR. We encourage you to familiarize yourself with these provisions. For our part, we deem it necessary to explain to you that the rights indicated above are not absolute and you will not be entitled to them in relation to all processing activities of your personal data.
We emphasize that one of the rights indicated above is always available to you: if you consider that we have violated data protection regulations in the processing of your personal data, you have the opportunity to file a complaint with the authority competent for personal data protection.
11: Is there anything else you should know about?
As you can see, the topics of personal data processing, the use of cookies and the management of privacy in general are quite complex. We have done our best to ensure that this document provides you with the most far-reaching knowledge on the issues that are important to you. If anything is unclear to you, you would like to learn more or just talk about your privacy, please email us at dribbledata@gmail.com.
12: Can this Privacy Policy be subject to change?
Yes, we may modify this Privacy Policy, in particular due to technological changes and changes in laws. If you are a registered user, you will receive a message about any change to the Privacy Policy. Changes to the Privacy Policy become effective after 7 days at the earliest. All archived versions of the Privacy Policy are linked below.
13:Cookies Policy
The Administrator on its website, as well as other entities, uses so-called "cookies", which are short text information stored on the user's computer, phone, tablet or other device. They can be read by our system.
While we respect the autonomy of everyone who uses the website, we feel obliged to warn you that disabling or restricting cookies may cause quite serious difficulties in using the website, such as having to log in to every subpage, longer loading times, restrictions on the use of functionality.
Last updated: 30/01/2024
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