Privacy Policy

Introduction

This policy describes and applies to the information we collect when using Dosen sites, Services, mobile applications, products, and content (“Services”). It also provides information about how we store, transfer, use, and delete that information and your choices concerning the information.

This policy applies where we are acting as a Data Controller concerning the personal data of users of our Services; in other words, we determine the purposes and means of processing that personal data. For content and data that you upload to or make available through the Service (“user content”), you are responsible for ensuring this content is per our Terms of Service and that the content is not violating other users’ privacy.

The data we collect and how we process and store information.

We at Dosen are committed to safeguarding the privacy of our users. We will only collect and process information that we need to deliver the Service to you and continue maintaining and developing the Service. This may include exporting program information and/or profile information of members to help your program with tasks such as member support, program reporting etc.

The following is a list of data we collect, process or store:

User account information

To use the Dosen Service, users might have to provide a valid email address, date of birth, full name, phone number, personal bio, headshot, video, time zone and currency. The user can also enter other information like their social media handles.

Transaction information

Users that register on Dosen, and users of their Services, might have to provide credit card information, billing email, banking information, location at the time of transaction and/or a billing address to complete a transaction. The transaction data may be processed to supply the purchased Services and keep proper records of those transactions. This data may be used to deliver the Services to you. Processing this information is required for fulfilling the contract we entered into with you at your request (our Terms of Service). Additionally, this information must be retained to comply with accounting and tax regulations.

Service Information

When you interact with the Service, we automatically store a recording of a video call on our server to use it for quality control, analytics and insight, training and mitigating user disputes of the Service, as explained in our FAQs, and performing the contract we entered into with you, at your request (our Terms of Service). If requested by either party, we will provide a copy of the call only if approved by the other party. If the user did not raise a dispute within the time defined in our FAQs, such recordings are automatically deleted.

Usage information

When you interact with the Services, we collect and process metadata to provide additional context about how the Service is being used. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, and information about the timing, frequency and pattern of your Service use. The source of the usage data is our server software and our analytics tracking system.

Product Analytics data

Dosen logs activities by you and other users when users interact with our Services, when a page or a call is initiated or where there is a conversation.

Technical log data

Like most digital Services, our servers automatically collect information when websites or Services are accessed or used and record it in log files. This log data may include the Internet Protocol (IP) address, the web page’s address visited within the Services, browser type and settings, the date and time the Services were used, browser configuration and plugins, language preferences, and cookie data.

Device information

Dosen may collect and process information about devices used to access the Services, including the type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect and process some or all of this information depends on the type of device used and its settings.

Location information

We receive information from you and other third parties that help us approximate your location. We may, for example, use a business address submitted by your employer or an IP address received from your browser or device to determine an approximate location. Dosen may also collect location information from devices per the consent process provided by your device.

The legal basis for this processing is our legitimate interests, namely using this data to ensure the proper administration of our Website and business, analyzing the use of the Website and services, monitoring and improving our Website and Services, improving the user experience, preventing abuse, and assisting users with support inquiries.

Customer Support Information

We may process the information you send to us if you submit a ticket to our support email. If you contact us, we may use your account, transaction or usage information to respond. Processing this information is required for performing the contract we entered into with you at your request (our Terms of Service) and our legitimate interest in handling your requests.

Service and transactional notifications

Sometimes we’ll send you emails about your account, Service changes or new policies. You can’t opt out of this type of ‘Service’ email (unless you delete your account) as they are necessary information for the Services. The legal grounds for processing this information is that it is required for performing our commitment to communicating changes in plans and pricing to you in the contract we entered into with you, at your request (our Terms of Service).

Correspondence information

We may process the information you choose to share with us if you participate in a focus group, contest, activity or event, apply for a job, interact with our social media accounts or otherwise communicate with Dosen. The correspondence data may be processed to communicate with you and record-keeping.

Providing your data to others

We may share information about you with third parties in some circumstances, including: (1) to a Service provider or partner who meets our data protection standards; (2) with academic or non-profit researchers, with aggregation, anonymization; (3) when we have a good faith belief it is required by law, such as according to a subpoena or other legal process; (4) to protect the vital interest of others when we have reason to believe that doing so will prevent harm to someone or illegal activities.

Our categories of Service providers and partners are:

  1. Hosting/infrastructure/storage providers
  2. Payment processors
  3. Analysis tools providers
  4. Customer Support tools providers
  5. Marketing and email providers
  6. Recruiting tools providers
  7. Internal communication tools providers

Business Transfers

We may disclose your data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes and on the legal basis set out in this policy. If we are involved in a merger, acquisition, bankruptcy, reorganization or sale of assets such that your information would be transferred or become subject to a different privacy policy, we will notify you in advance and give you the option to delete your data before the transfer.

Retaining and Deleting Personal Data

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Transaction information will be retained for a maximum period of 10 years following the transaction date.

In some cases, we can’t specify in advance the periods for which your data will be retained. In such cases, we will determine the period of retention based on the following criteria:

  1. The account information will be retained until you delete your Dosen account.
  2. Information about you used for product & marketing communication will be retained as long as you have given us consent to use this information.
  3. The retention period of usage information will be determined based on the need for historical data to determine statistical validity and relevance for product decisions and technical monitoring.

Regardless of the provisions above, we may retain your data where such retention is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.

Changes to This Policy

We can change these Terms at any time. We’ll let you know if a change is considered material before applying it. By using Dosen on or after that effective date, you agree to the new Terms. If you don’t agree to them, you should contact Dosen at [email protected] with the request to delete your account before they take effect; otherwise, your use of the Service and content will be subject to the new Terms.

Managing and deleting your personal information

If you have a Dosen account, you can access and modify your personal information from within the My Account section of your account. To delete your account, you should contact Dosen at [email protected]. If you request to delete your account, your information and content will be unrecoverable after that time. We may withhold personal information that you request to the extent permitted by law.

Your Rights

As an individual, you are granted rights according to the applicable data protection law:

  1. The right to access your data
  2. The right to rectification of your data
  3. The right to object to and restrict our processing of your data
  4. The right to data portability

To exercise your rights or if you otherwise have any questions regarding our processing of your data, we encourage you to contact us as described below. However, we also notify you that you may raise a complaint to a data protection authority. For any questions about this privacy policy, please contact [email protected].

 

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