Privacy Policy
DIGITAL TRUST CSP Fzco, based in Dubai, Digital Park, Dubai Silicon Oasis
(LICENSE no. 8213) (hereinafter: “Owner”), is constantly committed to
protecting the online privacy of its customers.
This document was drawn up pursuant to art. 13 of EU Regulation 2016/679
(hereinafter: “Regulation”) in order to allow you to know our privacy policy,
to understand how your personal information is managed when you use our
website www.digitaltrustcsp.com, or l Doublefi Wallet, DoubleFinance or Doublefi
app (hereinafter: “Site”) and, where appropriate, to give express and informed
consent to the processing of your personal data. The information and data
provided by you or otherwise acquired as part of the use of the services
available through the Site will be processed in compliance with the provisions
of the Regulation and the confidentiality obligations that inspire the Data
Controller’s activity.
According to the rules of the Regulation, the processing carried out by
the Data Controller will be based on the principles of lawfulness, correctness,
transparency, limitation of purposes and conservation, data minimization,
accuracy, integrity and confidentiality.
Index
- Data Controller
- Personal Data subject to processing
- Navigation data
- Data provided voluntarily by the data subject
- Cookie
- Purpose of the processing
- Legal Basis and Mandatory or Optional Nature of
the Processing
- Recipients of Personal Data
- Transfers of Personal Data
- Retention of Personal Data
- Rights of the data subject
- Use of the Site by Minors
- Changes
1.
Data Controller
The Data Controller of the processing carried out through the Site is
defined in the premises. For any information relating to the processing of
personal data by the Data Controller, you can write to the Data Controller at
the contact details indicated at the bottom.
DIGITAL TRUST CSP Fzco, based in Dubai, Digital Park, Dubai Silicon Oasis
(LICENSE No. 8213)
info@doublefinance.io
2.
Personal Data Being Processed
Following navigation of the Site, we inform you that the Data Controller
will process personal data which may consist of an identifier such as the name,
an identification number, an online identifier or one or more characteristic
elements of your physical, physiological, psychological, economic identity. ,
cultural or social suitable to make the interested party identified or
identifiable (hereinafter: “Personal Data”).
The Personal Data processed through the Site are as follows:
a. Navigation data
The computer systems and software procedures used to operate the Site acquire,
during their normal operation, some Personal Data whose transmission is
implicit in the use of Internet communication protocols. This is information
that is not collected to be associated with identified interested parties, but
which by its very nature could, through processing and association with data
held by third parties, allow users to be identified. This category of data
includes the IP addresses or domain names of the computers used by users who
connect to the Site, the addresses in URI (Uniform Resource Identifier)
notation of the requested resources, the time of the request, the method used
in submitting the server request, the size of the file obtained in response,
the numerical code indicating the status of the response given by the server
(successful, error, etc.) and other parameters relating to the operating system
and the user’s IT environment. These data are used for the sole purpose of
obtaining anonymous statistical information on the use of the Site and to check
its correct functioning, to identify anomalies and/or abuses, and are deleted
immediately after processing. The data could be used to ascertain
responsibility in the event of hypothetical computer crimes against the site or
third parties: except for this eventuality, the data on web contracts currently
do not persist for more than 1 month.
b. Data provided voluntarily by the interested party
When using some of the Site’s services (for example, via contact form),
the Personal Data of third parties sent by you to the Data Controller may be
processed. With respect to these hypotheses, you act as an independent data
controller, assuming all legal obligations and responsibilities. In this sense,
it grants the broadest indemnity on this point with respect to any dispute,
claim, request for compensation for damage caused by treatment, etc. that
should reach the Data Controller from third parties whose Personal Data have
been processed through their use of the Site’s functions in violation of the
applicable personal data protection regulations. In any case, if it provides or
otherwise processes the Personal Data of third parties when using the Site, it
guarantees up to now – assuming all related responsibility – that this
particular processing hypothesis is based on an appropriate legal basis
pursuant to art. 6 of the Regulation which legitimizes the processing of the
information in question.
c. Cookies
Cookies are small text files that the sites visited by the user send and
record on their computer or mobile device, to be then re-transmitted to the
same sites on the next visit. Thanks to cookies, a site remembers the user’s
actions and preferences (such as, for example, login data, the chosen language,
font size, other display settings, etc.) so that they do not have to be
indicated. again when the user returns to visit the Site or navigate from one
page to another. Cookies, therefore, are used to perform computer
authentication, monitor sessions and store information regarding the activities
of users who access a site and can also contain a unique identification code
that allows you to keep track of navigation on a site, the The user can also
receive cookies from sites or web servers other than the one he or she is
visiting on his or her computer (so-called “third-party” cookies). Some operations
could not be carried out without the use of cookies, which in certain cases are
therefore technically necessary for the functioning of the site. There are
various types of cookies, depending on their characteristics and functions, and
these can remain on the user’s computer for different periods of time:
so-called. session cookies, which remain on the user’s equipment until a
pre-established expiry date.
Based on current legislation in Europe, express user consent is not always
required for the use of cookies. In particular, “technical cookies” do not
require such consent, i.e. those used for the sole purpose of transmitting a
communication over an electronic communications network, or to the extent
strictly necessary to provide a service explicitly requested by the user. In
other words, these are cookies that are essential for the functioning of the
Site or necessary to carry out activities requested by the user.
Among the technical cookies, which do not require express consent for
their use, the European Guarantor for the protection of personal data (see
Provision Identification of simplified methods for the information and the
acquisition of consent for the use of cookies of the 8 May 2014 and subsequent
clarifications, hereinafter: “Provision”) also includes:
- “Analytics cookies” where used directly by the
site manager to collect information, in aggregate form, on the number of
users and how they visit the site itself;
- Navigation or session cookies (to authenticate);
- Functional cookies, which allow the user to
navigate according to a series of selected criteria (for example, the
language, the products selected for purchase) in order to improve the
service provided to the user.
For “profiling cookies”, on the other hand, i.e. those aimed at creating profiles
relating to the user and used for the purpose of sending advertising messages
in line with the preferences expressed by the user when browsing the internet,
prior consent is required from the user. ‘user.
Types of cookies used by the Site and possibility of (de-)selection
The Site uses the following cookies which can be de-selected, except for
third-party cookies for which you must refer directly to the relevant selection
and de-selection methods of the respective cookies, indicated via links.
Cookie Consent
Vendor: digitaltrustcsp.com
Scope: Stores the user’s cookie consent state for the current
domain.
Expiration: 1 year
Type: HTTP
Vendor: digitaltrustcsp.com
Scope: Registers a unique ID used to generate statistical data
on how the visitor uses the website.
Expiration: 2 years
Type: HTTP
Vendor: digitaltrustcsp.com
Scope: Used by Google Analytics to limit the request rate.
Expiration: Sessione
Type: HTTP
Vendor: digitaltrustcsp.com
Scope: Registers a unique ID used to generate statistical data
on how the visitor uses the website.
Expiration: Session
Type: HTTP
Vendor: google-analytics.com
Scope: Used to send data to Google Analytics about the
visitor’s device and behavior. Tracks visitor across devices and marketing
channels.
Expiration: Session
Type: Pixel
They are cookies from sites or web servers other than that of the Owner,
used for the purposes of said third parties. It should be noted that these
third parties, listed below with the relevant links to the privacy policies,
are typically independent data controllers of the data collected through the
cookies they serve; therefore, you must refer to their personal data processing
policies, information and consent forms (selection and de-selection of the
respective cookies), as specified in the aforementioned Provision. For the sake
of completeness, it is also specified that the Owner does his utmost to be able
to track cookies on his Site. These are updated regularly in the table below,
where we provide transparency on the cookies directly sent by the Owner and
their purposes. As regards third parties who send cookies via our Site, we
provide links to their respective privacy information below: as already
specified, we delegate to these third parties the responsibility of providing
the information and collecting your consent, as required by the Measure. This
responsibility refers not only to the cookies that third parties send directly,
but also to any additional cookies that are sent via our Site by virtue of the
use of services that the third parties themselves use. In fact, with respect to
these cookies, sent by service providers of the aforementioned third parties,
the Owner does not have the possibility of exercising any control and does not
know either their characteristics or purpose.
Below are the links to the information and consent forms of the third
parties that serve cookies via the Site:
- Google Analytics (Google Inc.)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize the ads of its advertising network. Personal Data Collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield Participant. - Google Analytics with anonymized IP
(Google Inc.)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of www.digitaltrustcsp.com, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize the ads of its advertising network. This Google Analytics integration anonymizes your IP address. Anonymization works by shortening the IP address of Users within the borders of the member states of the European Union or in other countries party to the Agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google servers and truncated within the United States. Personal data collected: Cookies and usage data. Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield Participant. - Google Fonts (Google Inc.)
Google Fonts is a service that allows you to incorporate and display custom font styles and is managed by Google Inc. Personal data collected: Cookies and usage data. Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield Participant. - Google reCAPTCHA (Google Inc.)
Google reCAPTCHA is a SPAM protection service provided by Google Inc.The use of the reCAPTCHA system is subject to Google’s privacy policy and terms of use.Personal data collected: Cookies and usage data. Place of processing: United States – Privacy Policy. Privacy Shield Participant.
Cookie Settings
You can block or delete (in whole or in part) technical and functional
cookies through the specific functions of your browser. However, we inform you
that not authorizing technical cookies may make it impossible to use the Site,
view its contents and use the related services. Inhibiting functionality
cookies may result in certain services or functions of the Site not being
available or not working properly and you may be forced to change or manually enter
certain information or preferences each time you visit the Site.
The choices made in relation to the Site’s cookies will in turn be
recorded in a special cookie. However, in some circumstances this cookie may
not function properly: in such cases, we advise you to delete the cookies you
do not like and to inhibit their use also through the functionality of your
browsers.
Your cookie preferences will need to be reset if you use different devices
or browsers to access the Site.
How to view and modify cookies through your browser
You can authorize, block or delete (in whole or in part) cookies through
the specific functions of your browser. For more information on how to set
preferences on the use of cookies through the Browser, you can consult the
relevant instructions:
3. Purpose of the Processing
- The Data Controller will use your Personal Data,
with your specific consent where necessary, for the following purposes:
- To allow the provision of the services requested
by you (request for contact, appointment, request for opinions and
information, etc.);
- To comply with any obligations provided for by
laws, regulations or EU legislation, or to comply with requests from
authorities;
- Carry out marketing activities, such as
processing statistics and market research, sending you information and
promotional material relating to the activities, products and services of
the Data Controller. If you decide to give your consent to receive
information relating to the Data Controller’s promotional activities,
including market research, we inform you that these activities may be
carried out, as provided for by current regulations, by means of paper
mail, telephone contacts through an operator (“traditional methods”),
e-mail, sending text messages and use of social networks (“automated
methods”). We also inform you that at any time you may decide to revoke
the consent previously granted by traditional or automated methods by
communicating it to the Data Controller without any formality through the
addresses below, without prejudice to the lawfulness of the processing
based on the consent given before the revocation.
4. Legal Basis and Mandatory or Optional Nature of the Processing
- The legal bases for the processing of Personal
Data for the purposes set out in section 3 above are:
- Provision of services (3.a): the
processing of Personal Data for this purpose is based on Article 6(1)(b)
of the Regulation (“[…] the processing is necessary for the
performance of a contract to which the data subject is a party or for the
execution of pre-contractual measures adopted at the request of the same”).
The provision of Personal Data for these purposes is optional, but
failure to provide it would make it impossible to activate the services
provided by the Site and/or respond to your requests;
- Fulfilment of legal obligations (3.b): the
processing of Personal Data for this purpose is based on Article 6(1)(c)
of the Regulation (“[…] processing is necessary for compliance with a
legal obligation to which the controller is subject”);
- Marketing (3.c): the
processing of Personal Data for this purpose is based on the issuance of
your consent pursuant to Article 6(1)(a) of the Regulation (“[…] the
data subject has given consent to the processing of his/her personal data
for one or more specific purposes”). The provision of your Personal
Data for this purpose is therefore entirely optional and does not affect
the use of the services. If you wish to object to the processing of your
Personal Data for marketing purposes, you may do so at any time by
contacting the Data Controller at the addresses indicated in section 8
below.
5. Recipients of Personal Data
- Your Personal Data may be shared, for the
purposes set out in section 3 above, with the following persons and/or
entities (collectively “Recipients”):
- Subjects who typically act as data processors, namely:
- Persons, companies or professional firms that
provide assistance and advice to the Data Controller in accounting,
administrative, legal, tax, financial and debt collection matters
relating to the provision of services;
- Subjects with whom it is necessary to interact
for the provision of services (e.g. hosting providers);
- Subjects delegated to carry out technical
maintenance activities (including the maintenance of network equipment
and electronic communication networks).
- Subjects, bodies or authorities to whom it is
mandatory to communicate your Personal Data by virtue of legal
provisions, regulations or orders of the authorities;
- Persons authorised by the Data Controller to
process Personal Data necessary to carry out activities strictly related
to the provision of services, who have committed themselves to
confidentiality or have an adequate legal obligation of confidentiality
(e.g. employees/collaborators of the Data Controller).
6. Transfers of Personal Data
Your Personal Data is not transferred outside the European Economic Area.
7. Retention of Personal Data
The Personal Data processed for the provision of services (3.a) will be
kept for the time strictly necessary to achieve those purposes. In any case,
since the processing is carried out for the provision of services, the Data
Controller will process the Personal Data for as long as allowed by European
law to protect its rights and interests.
Personal Data processed for the fulfilment of legal obligations (3.b) will
be kept for the time provided for by the specific obligation or rule of law or
applicable regulation.
Personal Data processed for marketing purposes (3.c) will be processed
until your consent is withdrawn.
Further information regarding the data retention period and the criteria
used to determine this period can be requested by writing to the Data
Controller at the addresses indicated below.
8. Rights of data subjects
Pursuant to articles 15 et seq. of the Regulation, you have the right to
ask the Data Controller, at any time, for access to your Personal Data, the
correction or deletion of the same or to object to their processing, you have
the right to request the limitation of processing in the cases provided for by
art. 18 of the Regulation, as well as to obtain the data concerning you in a
structured, commonly used and machine-readable format, in the cases provided
for by art. 20 of the Regulation.
Requests Must Be Sent In
Writing To The Data Controller At The Following Address:
DIGITAL TRUST CSP Fzco, based in Dubai, Digital Park, Dubai Silicon Oasis
(LICENSE No. 8213)
In any case, you always have the right to lodge a complaint with the
competent Supervisory Authority (Guarantor for the Protection of Personal
Data), pursuant to art. 77 of the Regulation, if you believe that the processing
of your Personal Data is contrary to the regulations in force.
9. Use of the Site by minors
The Site is intended for persons over the age of 16 and parental consent
is required until the age of 16. We ask that children under the age of 16 do
not provide Personal Data through the Site. We reserve the right to request, at
any time, proof of parental consent to allow the processing of Personal Data
relating to minors.
10. Changes
The Data Controller reserves the right to modify or simply update its
content, in part or in full, also due to changes in the applicable legislation.
The Data Controller will inform you of such changes by means of a notice
published on the Site. The Data Controller therefore invites you to regularly
visit this section to familiarize yourself with the most recent and updated
version of the privacy policy in order to be always updated on the data
collected and the use that is made of it.