Privacy Policy

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We at Dora Platform PTE Ltd. (collectively with any subsidiaries, “Dora”) have created this Privacy Policy to describe our practices regarding information we collect through our website and any other interactive features or services owned or controlled by Dora (each, a "Service" and collectively, the "Services"), as well as any information we collect offline and combine in our databases. Dora are the Data Controller of your personal data and can be contacted at the contact details given at the end of this Privacy Policy. Note that we combine and process the information we collect through our website and other Services in accordance with the terms set out in this Privacy Policy. SCOPE This Privacy Policy applies to personal information processed by us in our business globally through our Services. 1. PERSONAL INFORMATION WE COLLECT. The categories of personal information we collect depend on whether you are a user or visitor, and the requirements of applicable law. Information You Provide to Us. Account Creation. When you create a user account, we collect your name, email address, password and we may ask you to optionally (or not optionally) provide demographic or other information such as your time zone, gender, age or birthdate, zip or postal code, etc. Profile Creation. You may have the opportunity to create a profile which may include photographs and information about your interests and activities. Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, apply for a job, or otherwise communicate with us by any means or medium. Payment and Financial Information. We will process your payment information if you purchase products or services through our Services. Note that we do not store payment credit or debit card numbers. If you utilize the Services in a way that necessitates payment from Dora to you (such as offering services for sale through Dora or participating in research projects), we may collect additional information from you as necessary to facilitate payment and to comply with related legal obligations. Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information. Social Media Content. We may offer forums, blogs, or social media pages which you are free to participate in at your own discretion. Any content you provide on these channels will be “public” and therefore can be seen by other users. Information Collected Automatically or from Others. Automatic Data Collection. We may collect certain information automatically when you use the Services including your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet or mobile service provider, pages that you visit before, during, and after using the Services, information about the links you click, and other information about how you use the Services. In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. Cookie policy We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services. Kindly visit our Cookies Policy for more information on how we use cookies. Third Party Technologies. Third party cookies are set by someone other than the website you are actually visiting. We may use third party cookies to provide services and evaluate the use of the website. We use the following types of Technologies: - Cookies Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly. Session cookies are stored only for the time you are using the website and are deleted when you close your browser, whereas permanent cookies are stored on your device for a certain period or until you manually remove them. - Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. - Embedded Scripts. Embedded scripts are programming code designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third-party service provider and is deactivated or deleted when you disconnect from the Services. - Flash & HTML5. We use Local Storage Objects (“LSOs”) such as HTML5 to store content, information, and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your web browsing activity use LSOs such as HTML 5 & Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. Information from Other Sources. We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site or you log in to a third party’s service using your Dora credentials, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email address or other contact information, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services. Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. HOW WE USE YOUR INFORMATION. We use your information for a variety of business purposes, including to: Fulfil our contract with you and provide you with our Services, such as: - Managing your information and accounts; - Providing access to certain areas, functionalities, and features of our Services; - Communicating with you about activities on our Services and policy changes; - Undertaking activities to verify or maintain the quality or safety of a service or device; - Processing your financial information and other payment methods for products or Services purchased; - Processing transactions and applications; Analyze and improve our Services pursuant to our legitimate interest, such as: - Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity; - Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads; - Undertaking research for technological development and demonstration; - Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability, or efficiency; - Improving, upgrading, or enhancing our Services; - Developing new products and Services; - Ensuring internal quality control; - Verifying your identity and preventing fraud; - Debugging to identify and repair errors that impair existing intended functionality; - Enforcing our terms and policies; and - Furnishing you with customized materials about offers, products, and services that may be of interest, including new content, product, or Services. Comply with our legal obligations, for example auditing relating to interactions, transactions, and other compliance activities. Protect your vital interest or as may be required for the public good. Other purposes you may consent to, are notified of, or are disclosed when you provide personal information. Automated profiling. We may use technologies considered automated decision making or profiling. We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to use such technology. You may escalate any concerns you have by contacting us below. Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Testimonials. We may display personal testimonials of satisfied customers on our Services in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us as indicated below. Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location, and device identifiers, and will match the information of the browser and devices that appear to be used by the same person. Notice Regarding Third-Party Websites. The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk. Social Media and Other Publicly Accessible Forums. Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such Services, you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes. In addition, social media buttons such as Facebook, Instagram, YouTube, Twitter, Pinterest, and LinkedIn (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it. APIs and SDKs. We may use third-party application programming interface (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below. 2. DISCLOSING YOUR INFORMATION TO THIRD PARTIES. Except as provided below, we do not share/disclose/sell your personal information. We do not share your Personal Information with third parties for their marketing purposes without your consent. We may share non-Personal Information (such as aggregate user statistics, de-identified information, demographic information such as gender, age, graduation years, and other related information), and Usage Information with third parties, including advertisers, content providers, and analytics providers; and third parties may collect non-Personal Information when you visit the Services. When You Request That We Share Your Information. We may offer opportunities and features through the Services that are brought to you by a third party or that otherwise involve sharing your information with a third party. If you request, direct us or agree at that time to have your information shared, your information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. This includes, without limitation, instances in which you use our Services to purchase products or services provided, in whole or part, by third parties. You also may request, sometimes through your use of an interactive feature or social media feature, that we share information about you with a third party or publicly. Contests and Promotions. We may offer contests and other promotions ("Promotion") that may require registration. By participating in a Promotion, you are agreeing to governing terms, conditions, or official rules, which may contain specific requirements of you, including allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information, such as your name and shipping address, may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list. Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include: IT and related services; payment processors; customer service providers; fraud detection and prevention providers, security and risk management providers, and other vendors to support the provision of the Services. For details of the current third parties we use, please contact us to find out more. Business Partners. We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours. Advertising Partners. Through our Services and if your consent has been sought in accordance with our Cookie Policy, we may allow third-party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit the third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable, or otherwise of interest to you. If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below. Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; detect or prevent fraud; or assist with an investigation or prosecution of suspected or actual illegal activity. Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract. International Data Transfers. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, the United Kingdom, Canada, Israel, India or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request using the contact details below. Please note that your personal information will be accessible to law enforcement and/or regulatory authorities according to the applicable laws of such foreign jurisdictions. 3. YOUR CHOICES. General. You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above. You are not required to provide us with personal information, but we may not be able to provide you with access to certain products and services if you do not provide us with the information we request. Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy). We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law. Mobile Devices. You may be able to opt-in to receiving text messages from Dora. You may opt-out by replying "STOP" to one of the text messages received. We will send you push notifications if you agree to receive them regarding updates on the Services and other items that may be relevant to you. “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. Instead, you can stop or restrict the placement of tracking cookies on your device as set out in the paragraph below. Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice. Please note you must separately opt out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes. 4. YOUR RIGHTS If you reside in the United Kingdom, you have the following rights regarding your personal data: 1. Rights to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy. 2. Right of access. You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this Privacy Policy). This is so you are aware and can check that we are using your personal data in accordance with data protection law. 3. Right to rectification. You are entitled to have your personal data corrected if it is inaccurate or incomplete. 4. Right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enable you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. 5. Right to restrict processing. You have the right to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further. 6. Right of data portability. You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party. 7. Right to object to processing. You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including in each case any related profiling). 8. Right to withdraw consent to processing. If you have given your consent to us to process your personal data for a particular purpose (for example, direct marketing), you have the right to withdraw your consent at any time (although if you do so, it does not mean that any processing of your personal data up to that point is unlawful). 9. Right to make a complaint to the data protection authorities. You have the right to make a complaint to the Information Commissioner’s Office (ICO) if you are unhappy with how we have handled your personal data or believe our processing of your personal data does not comply with data protection law 5. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies to individuals, who reside in the State of California (”consumers” or “you”). We adopt this notice along with the Privacy Policy to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. Information We Collect We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

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We obtain the categories of Personal Information listed above from the following categories of sources: - Directly from you. For example, from forms you complete on our website. - Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers, - From Third Parties such as third parties you use to log in to our Services. Disclosures of Personal Information for a Business Purpose We may disclose your Personal Information to a service provider or a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information in our role as a business for a business purpose: Category A: Identifiers Category B: Personal information categories in Cal. Customer Records statuteCategory C: Commercial information Category D: Internet information Category E: Geolocation Category F: Professional or employment-related information Category G: Non-public education information Category H: Inferences We disclose your Personal Information for a business purpose to the following categories of third parties: - Our affiliates - Service providers - Advertising networks, internet service providers, data analytics providers, government entities, operation systems and platforms, social networks and consumer data resellers - Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you. Sales of Personal Information In the preceding twelve (12) months, we have sold the following categories of Personal Information for valuable consideration: Category A: Identifiers Category D: Internet information Category E: Geolocation Your Rights and Choices The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. Access to Specific Information and Data Portability Rights You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: - The categories of Personal Information we collected about you. - The categories of sources from which the Personal Information is collected about you. - Our business or commercial purpose for collecting or selling that Personal Information. - The categories of third parties with whom we share that Personal Information. - The specific pieces of Personal Information we collected about you (also called a data portability request). - If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: - sales, identifying the Personal Information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Deletion Request Rights You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: - Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. - Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. - Debug products to identify and repair errors that impair existing intended functionality. - Exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise another right provided for by law. - Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). - Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the business’ deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. - Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. - Comply with a legal obligation. - Make other internal and lawful uses of that information that are compatible with the context in which you provided it. Exercising Access, Data Portability, and Deletion Rights To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending logging into your account or by emailing [email protected]. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child (12 and under). You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: - Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. - Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or your authority to make the request and confirm the Personal Information relates to you. In some instances, if we cannot verify your identity to provide you access to personal information, you may choose to delete such personal information. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Response Timing and Format Where possible, we will respond to a verifiable consumer request within forty-five (45) days of its receipt; however, if we require more time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Personal Information Sales Opt-Out and Opt-In Rights (“Do Not Sell My Info”) You have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing [email protected]. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by emailing us at [email protected]. We will only use Personal Information provided in an opt-out request to review and comply with the request. Non-Discrimination We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: - Deny you goods or services. - Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. - Provide you a different level or quality of goods or services. - Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer, will reasonably relate to your Personal Information’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. Authorized Representative You may designate an authorized agent to make a request under the CCPA on the consumer’s behalf by emailing us from the email address associated with your account, indicating: your name, the fact that you would like to indicate an authorized agent, the name of your authorized agent, and the email address of your authorized agent. 1. DATA RETENTION. We store the personal information we receive as described in this Privacy Policy for as long as you use our Services, until you request its deletion, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, prevent fraud, and comply with applicable laws. 7. SECURITY OF YOUR INFORMATION. We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure. By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail, or by sending an email to you. 8. OTHER PROVISIONS. Supervisory Authority. If you are located in the European Economic Area, the UK, Canada, or Australia you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law. Changes to Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.