1. Privacy Policy Overview

Summary – Policy Overview

This Policy explains how we may Process your information. This Policy may be amended or updated from time to time, so please check it regularly for updates.
Dochet LTD, with its affiliates and its subsidiaries (collectively “us”, “our” or “we”), owns, operates, or provides access to, several interactive websites, mobile and connected applications, and other online interactive features and services, including, but not limited to, emails, newsletters, chat areas, forums, communities, sweepstakes and contests (collectively “Services”). This Privacy Policy applies to all information collected about you by Dochet LTD, regardless of how it is collected or stored, and describes, among other things, the types of information collected about you when you interact with the Services, how your information may be used, when your information may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.
Except as otherwise noted in this Privacy Policy, Dochet LTD is a data controller (as that term is used under the EU General Data Protection Regulation (“GDPR”)), which means that we decide how and why the information you provide to us is processed. This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make.
This Privacy Policy covers information collected through the following websites and mobile applications:

• Instagram web and mobile app

2. What Categories of Information We May Process

Summary – Categories of Information We May Process

We may Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.
We may also Process depersonalized data about IG users from your use of our Services (e.g., the type of device they are using, their age, location, etc.), including your interactions with content and advertising on the Services.
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We may Process the following categories of Personal Information about you:

• Personal details: your name; username or log in details; password; areas or topics of interest; and photograph (if you or another user posts a photo on the Service).
• Demographic information: gender; age/date of birth; nationality; salutation; job title, company information, education, work experience and other professional information; and language preferences.
• Contact details: postal address; telephone and/or mobile number; email address; and your public social media handles or profile(s).
• Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
• Location information: location data that describes the precise geographic location of your device (“Precise Location Data”).
• Purchase and payment details: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or accountholder name; payment amount; and payment date.
• Employer details: where you interact with us in your capacity as an employee, the contact information of your employer (including name, address, telephone number and email address) to the extent relevant.
• Views and opinions: any views and opinions that you or other users choose to send to us, or publicly post about us on social media platforms or in the Services, including on forums.

We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:

• Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
• Browsing history including the websites or other services you visited before and after interacting with the Services.
• Searches for and interactions with e-commerce opportunities, such as merchants and offers contained in the Services.
• Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).
• Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
• Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a third party website.
• Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5.
• Mobile analytics to understand the functionality of our mobile applications and software on your phone.

Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.

3. Sensitive Personal Information

Summary – Sensitive Personal Information

We do not seek to collect or otherwise Process your Sensitive Personal Information. Where we need to Process your Sensitive Personal Information for a legitimate purpose, we do so in accordance with applicable law. The Services are not intended for use by children.
We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, “Sensitive Personal Information”) in the ordinary course of our business. Where it becomes necessary to Process Sensitive Personal Information under GDPR, we would rely on one of the following legal bases:

• Compliance with applicable law: We may Process your Sensitive Personal Information where the Processing is required or permitted by applicable law;
• Detection and prevention of crime: We may Process your Sensitive Personal Information where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
• Establishment, exercise or defense of legal rights: We may Process your Sensitive Personal Information where the Processing is necessary for the establishment, exercise or defense of legal rights; or
• Consent: We may Process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information.

Children. The Services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or chats. Minors under the age of 18 are not permitted to make purchases through the Services or obtaining coupons or codes from the Services to purchase goods or services on third party websites. If, notwithstanding these prohibitions, your children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.

4. How We Collect or Create Information

Summary – Collection and Creation of Information

We may collect or obtain User Information about you: directly from you (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make your Personal Information public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Services; when you visit our Services; when you register to use any part of the Services; or when you interact with any third party content or advertising on the Services. We may also receive User Information about you from third parties (e.g., social network sites). We may also create User Information about you, such as records of your interactions with us. Dochet LTD is not responsible for Personal Information you volunteer about yourself in public areas of the Services. This Policy does not cover the practices of third parties who may provide information about you to Dochet LTD.
Collection of User Information: We may collect User Information about you from the following sources:

• Data you provide: We may obtain your Personal Information when you provide it to us across our Services (e.g., where you sign up for emails, newsletters, bulletins, webinars or white papers; register for site membership or create a profile or account on any part of the Services; enter a sweepstakes, contest, competition or prize draw; receive promotional information by SMS text message; participate in surveys; perform search queries through the Services; contact us via email, telephone or by any other means; purchase a subscription, software license or product; or when you provide us with your business card, etc.).
• Relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g., if you purchase a service from us).
• Data you make public: We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us) or through our chats, forums or communities on the Services.
• Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our Service.
• Content and advertising information: If you choose to interact with any third party content or advertising on the Services or Channels, we may receive User Information about you from the relevant third party.
• Third party information: We may collect or obtain your Personal Information from third parties who provide it to us. This may include offline channels such as through telephone or direct mail efforts; from customers, vendors, suppliers, third parties, commercially available or publicly-available sources (e.g., data brokers, data aggregators, public databases, etc.); third party affiliate network operators; referral sources; social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.). If you use a third party connection or log-in (e.g., Facebook Connect, Twitter, or Google+) to access the Services, create a membership or profile on any part of the Services, access our content or forward our content to another person, platform or service, we may also receive your username or email address for those third party services or other information available about you or collected from you on those services.

Please note that Dochet LTD is not responsible for the information you volunteer about yourself in the discussions in certain public areas of the Services, such as forums, blogs, wikis, chat rooms, private messages, message boards or other publicly accessible interaction, or information that you choose to make public in your member profile or other areas of the Services that allow users to upload or post content. We discourage users from posting such Personal Information in this fashion. You can change your publicly available information at any time via your profile page. To request removal of your Personal Information from these areas, please contact us using our DSAR Portal. In some cases, we may not be able to remove your Personal Information, in which case we will let you know we are unable to do so and why.
This Privacy Policy does not cover the practices of third parties, including those that may disclose information to Dochet LTD.
Creation of User Information. We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis. We may also combine data you have provided to us with data obtained from third parties such as social networks and other data collection entities.

5.Purposes for Which We May Process Your Information

Summary – Purposes for Which We May Process Your Information

We may Process User Information for the following purposes: providing the Services to you; communicating with you; providing advertising to you on the Services and Channels; analyzing engagement with our audience; observing user engagement and purchase activity across the Service and Channels; ensuring the security of our systems; conducting investigations where necessary; compliance with applicable law; and improving our Services.
The purposes for which we may Process User Information, subject to applicable law, include:

• Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you as set out in Section 6 below.
• Audience Engagement: identification and development of audience engagement, advertising and promotional strategies on various platforms and channels, both within the Service and on Channels.
• User Engagement and Purchases: tracking purchase traffic and activity across the Service and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made.
• Marketing to Customers: We may market to current and prospective customers and their employees who have indicated an interest in doing business with, or have previously conducted business with, Dochet LTD in order to further generate and promote our business. Such efforts include sending marketing emails or conducting phone calls to drive the purchase of advertising, Online Data licensing, lead generation and other business services offered by Dochet LTD.
• IT Administration: administration of Dochet LTD information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.

6. What Information We Disclose to Third Parties

Summary – Disclosure of User Information to Third Parties

We may disclose your User Information to: legal and regulatory authorities; our external advisors; parties who Process User Information on our behalf (“Processors”); any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on the Services.
We may disclose your User Information to:

• legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
• any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;

For some of our Services, we may make some information, such as the name of our users, their mailing address, phone number, email address—and in certain circumstances their employer’s name, company size and other industry data—available on a rental or other basis (e.g., sale) to third party providers of goods and services, for example, when such information is provided in connection with webcasts, white papers or other sponsored downloads.
If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.
The Services contain links to other sites or partners whose information practices may be different from ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

7. International Transfers of Information

Summary – International Transfers of Information

We may transfer your Personal Information to recipients in other countries. Dochet LTD participates in the E.U.-U.S. Privacy Shield, the Swiss-U.S. Privacy Shield and the APEC Cross Border Privacy Rules System. Where we transfer User Information from the European Economic Area (“EEA”) to a recipient outside the EEA that is not in an adequate jurisdiction, we do so on the basis of standard contractual clauses.
Because of the international nature of our business, we may need to transfer your User Information within the Dochet LTD, and to third parties as noted in Section 6 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Where we transfer your Personal Information from the EEA to recipients located outside the EEA who are not in a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Information, we do so on the basis of standard contractual clauses.
Please note that when you transfer any Personal Information directly to a Company entity established outside the EEA, we are not responsible for that transfer of your Personal Information. We will nevertheless Process your Personal Information, from the point at which we receive the data, in accordance with the provisions of this Privacy Policy.

8. Data Security

Summary – Data Security

We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any Personal Information that you send to us is sent securely.
We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.

9. Data Accuracy

Summary – Data Accuracy

We take every reasonable step to ensure that your User Information is kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.
We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.

10. Data Minimization

Summary – Data Minimization

We take every reasonable step to limit the volume of your User Information that we Process to what is necessary.
We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.

11. Data Retention

Summary – Data Retention

We take every reasonable step to ensure that your User Information is only retained for as long as they are needed. Online Data related to OBA is kept by Dochet LTD for not more than 180 days after which it will expire, subject to certain conditions.
We take every reasonable step to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.
Except as may be set forth in this Privacy Policy, Online Data related to OBA is retained by Dochet LTD for not more than 180 days after which it shall expire. However, the 180 day period may commence again if the same user subsequently visits or interacts with an ad, email, the Services or a Channel.

12. What Can I Do to Control My Information?

Summary – What Can I Do to Control My Information?

EU Residents. GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the You can revoke your consent and subscriptions any time, with effect for the future, by notifying us per email, fax or letter.
If you would like to revoke your consent or unsubscribe from our emails, you will find a link to unsubscribe at the end of each email you receive from us. Or you can send an email and indicate the email address for which you do no longer want to receive any email information.