Privacy Policy
Last updated September 15, 2023
This privacy notice for Igor Chvalun ( 'we',
'us', or 'our'),
describes how and why we might collect, store, use, and/or share ( 'process' ) your
information when you use our services ( 'Services' ), such as when
you:
- Visit our website at https://docion.com, or any website of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy
notice will help you understand your privacy rights and choices. If you do not agree with our
policies and practices, please do not use our Services. If you still have any questions or
concerns, please contact us at [email protected] .
SUMMARY OF KEY
POINTS
This summary provides key
points from our privacy notice, but you can find out more details about any of these topics
by clicking the link following each key point or by using ourtable of contentsbelow to find the section you
are looking for.
What personal information do we
process? When you visit, use, or navigate our Services, we may process personal
information depending on how you interact with us and the Services, the choices you make, and the
products and features you use. Learn more aboutpersonal
information you disclose to us.
Do we process any sensitive
personal information? We do not process sensitive personal information.
Do we receive any information
from third parties? We do not receive any information from third parties.
How do we process your
information? We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and to comply with law. We may
also process your information for other purposes with your consent. We process your information only
when we have a valid legal reason to do so. Learn more abouthow we process your information.
In what situations and with which
parties do we share personal information? We may share information in specific
situations and with specific third parties. Learn more aboutwhen and with whom we share your personal
information.
How do we keep your information
safe? We have organisational and technical processes and procedures in place to protect
your personal information. However, no electronic transmission over the internet or information
storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security
and improperly collect, access, steal, or modify your information. Learn more abouthow we keep your information safe.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have
certain rights regarding your personal information. Learn more aboutyour privacy rights.
How do you exercise your
rights? The easiest way to exercise your rights is by visiting [email protected] , or
by contacting us. We will consider and act upon any request in accordance with applicable data
protection laws.
Want to learn more about what we do with
any information we collect?Review the privacy notice in
full.
TABLE OF
CONTENTS
1. WHAT
INFORMATION DO WE COLLECT?
Personal information you disclose to us
In
Short:We collect personal information that you
provide to us.
We collect
personal information that you voluntarily provide to us when you register on the
Services,express an
interest in obtaining information about us or our products and Services, when you
participate in activities on the Services, or otherwise when you contact
us.
Personal Information Provided by You. The
personal information that we collect depends on the context of your interactions with us and the
Services, the choices you make, and the products and features you use. The personal information
we collect may include the following:
- names
- email addresses
- mailing addresses
- job titles
- usernames
- passwords
- contact or authentication data
Sensitive Information.
We do not process sensitive information.
Social
Media Login Data. We may provide you with the option to register with us using your
existing social media account details, like your Facebook, Twitter, or other social media
account. If you choose to register in this way, we will collect the information described in the
section called ' HOW DO WE HANDLE YOUR SOCIAL
LOGINS? ' below.
All personal
information that you provide to us must be true, complete, and accurate, and you must notify us
of any changes to such personal information.
Information automatically collected
In
Short:Some information — such as your Internet
Protocol (IP) address and/or browser and device characteristics — is
collected automatically when you visit our
Services.
We
automatically collect certain information when you visit, use, or navigate the Services. This
information does not reveal your specific identity (like your name or contact information) but
may include device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device name, country,
location, information about how and when you use our Services, and other technical information.
This information is primarily needed to maintain the security and operation of our Services, and
for our internal analytics and reporting purposes.
Like many
businesses, we also collect information through cookies and similar technologies. You can find
out more about this in our Cookie Notice: docion.com/policy/cookies .
The information
we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps' ), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
2. HOW DO WE
PROCESS YOUR INFORMATION?
In Short:We process
your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with
law. We may also process your information for other purposes with your
consent.
We
process your personal information for a variety of reasons, depending on how you interact
with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3.
WHAT LEGAL BASES DO WE
RELY ON TO PROCESS YOUR
INFORMATION?
In
Short: We
only process your
personal information
when we believe it is
necessary and we have a
valid legal reason (i.e.
legal basis) to do so
under applicable law,
like with your consent,
to comply with laws, to
provide you with
services to enter into
or fulfil our
contractual obligations,
to protect your rights,
or to fulfil our
legitimate business
interests.
If
you are located
in the EU or UK,
this section
applies to
you.
The
General Data Protection
Regulation (GDPR) and UK
GDPR require us to explain
the valid legal bases we
rely on in order to process
your personal information.
As such, we may rely on the
following legal bases to
process your personal
information:
- Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more aboutwithdrawing your consent.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Send users information about special offers and discounts on our products and services
- Analyse how our Services are used so we can improve them to engage and retain users
- Support our marketing activities
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can improve user experience
- Legal
Obligations.
We may process
your information
where we believe
it is necessary
for compliance
with our legal
obligations,
such as to
cooperate with a
law enforcement
body or
regulatory
agency, exercise
or defend our
legal rights, or
disclose your
information as
evidence in
litigation in
which we are
involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If
you are
located
in
Canada,
this
section
applies
to
you.
We
may process your
information if you
have given us
specific permission
(i.e. express
consent) to use your
personal information
for a specific
purpose, or in
situations where
your permission can
be inferred (i.e.
implied consent).
You
canwithdraw
your
consentat
any
time.
In
some exceptional
cases, we may be
legally permitted
under applicable law
to process your
information without
your consent,
including, for
example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
In
Short:We may share
information
in specific
situations
described in
this section
and/or with
the
following
third
parties.
We
may need to share
your personal
information in the
following
situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
In
Short:We
may
use
cookies
and
other
tracking
technologies
to
collect
and
store
your
information.
We
may
use
cookies
and
similar
tracking
technologies
(like
web
beacons
and
pixels)
to
access
or
store
information.
Specific
information
about
how
we
use
such
technologies
and
how
you
can
refuse
certain
cookies
is
set
out
in
our
Cookie
Notice:
docion.com/policy/cookies.
In
Short:If
you
choose
to
register
or
log
in
to
our
Services
using
a
social
media
account,
we
may
have
access
to
certain
information
about
you.
Our
Services
offer
you
the
ability
to
register
and
log
in
using
your
third-party
social
media
account
details
(like
your
Facebook
or
Twitter
logins).
Where
you
choose
to
do
this,
we
will
receive
certain
profile
information
about
you
from
your
social
media
provider.
The
profile
information
we
receive
may
vary
depending
on
the
social
media
provider
concerned,
but
will
often
include
your
name,
email
address,
friends
list,
and
profile
picture,
as
well
as
other
information
you
choose
to
make
public
on
such
a
social
media
platform.
We
will
use
the
information
we
receive
only
for
the
purposes
that
are
described
in
this
privacy
notice
or
that
are
otherwise
made
clear
to
you
on
the
relevant
Services.
Please
note
that
we
do
not
control,
and
are
not
responsible
for,
other
uses
of
your
personal
information
by
your
third-party
social
media
provider.
We
recommend
that
you
review
their
privacy
notice
to
understand
how
they
collect,
use,
and
share
your
personal
information,
and
how
you
can
set
your
privacy
preferences
on
their
sites
and
apps.
7.
IS
YOUR
INFORMATION
TRANSFERRED
INTERNATIONALLY?
In
Short:We
may
transfer,
store,
and
process
your
information
in
countries
other
than
your
own.
Our
servers
are
located
in
the
United
States.
If
you
are
accessing
our
Services
from
outsidethe
United
States,
please
be
aware
that
your
information
may
be
transferred
to,
stored,
and
processed
by
us
in
our
facilities
and
by
those
third
parties
with
whom
we
may
share
your
personal
information
(see
'WHEN
AND
WITH
WHOM
DO
WE
SHARE
YOUR
PERSONAL
INFORMATION?'
above),
inthe
United
States,and
other
countries.
If
you
are
a
resident
in
the
European
Economic
Area
(EEA),
United
Kingdom
(UK),
or
Switzerland,
then
these
countries
may
not
necessarily
have
data
protection
laws
or
other
similar
laws
as
comprehensive
as
those
in
your
country.
However,
we
will
take
all
necessary
measures
to
protect
your
personal
information
in
accordance
with
this
privacy
notice
and
applicable
law.
8.
HOW
LONG
DO
WE
KEEP
YOUR
INFORMATION?
In
Short:We
keep
your
information
for
as
long
as
necessary
to
fulfil
the
purposes
outlined
in
this
privacy
notice
unless
otherwise
required
by
law.
We
will
only
keep
your
personal
information
for
as
long
as
it
is
necessary
for
the
purposes
set
out
in
this
privacy
notice,
unless
a
longer
retention
period
is
required
or
permitted
by
law
(such
as
tax,
accounting,
or
other
legal
requirements).
No
purpose
in
this
notice
will
require
us
keeping
your
personal
information
for
longer
than
twelve
(12)
months
past
the
start
of
the
idle
period
of
the
user's
account
.
When
we
have
no
ongoing
legitimate
business
need
to
process
your
personal
information,
we
will
either
delete
or
anonymise
such
information,
or,
if
this
is
not
possible
(for
example,
because
your
personal
information
has
been
stored
in
backup
archives),
then
we
will
securely
store
your
personal
information
and
isolate
it
from
any
further
processing
until
deletion
is
possible.
9.
HOW
DO
WE
KEEP
YOUR
INFORMATION
SAFE?
In
Short:We
aim
to
protect
your
personal
information
through
a
system
of
organisational
and
technical
security
measures.
We
have
implemented
appropriate
and
reasonable
technical
and
organisational
security
measures
designed
to
protect
the
security
of
any
personal
information
we
process.
However,
despite
our
safeguards
and
efforts
to
secure
your
information,
no
electronic
transmission
over
the
Internet
or
information
storage
technology
can
be
guaranteed
to
be
100%
secure,
so
we
cannot
promise
or
guarantee
that
hackers,
cybercriminals,
or
other
unauthorised
third
parties
will
not
be
able
to
defeat
our
security
and
improperly
collect,
access,
steal,
or
modify
your
information.
Although
we
will
do
our
best
to
protect
your
personal
information,
transmission
of
personal
information
to
and
from
our
Services
is
at
your
own
risk.
You
should
only
access
the
Services
within
a
secure
environment.
10.
DO
WE
COLLECT
INFORMATION
FROM
MINORS?
In
Short:We
do
not
knowingly
collect
data
from
or
market
to
children
under
18
years
of
age
.
We
do
not
knowingly
solicit
data
from
or
market
to
children
under
18
years
of
age.
By
using
the
Services,
you
represent
that
you
are
at
least
18
or
that
you
are
the
parent
or
guardian
of
such
a
minor
and
consent
to
such
minor
dependent’s
use
of
the
Services.
If
we
learn
that
personal
information
from
users
less
than
18
years
of
age
has
been
collected,
we
will
deactivate
the
account
and
take
reasonable
measures
to
promptly
delete
such
data
from
our
records.
If
you
become
aware
of
any
data
we
may
have
collected
from
children
under
age
18,
please
contact
us
at
[email protected]
.
11.
WHAT
ARE
YOUR
PRIVACY
RIGHTS?
In
Short:In
some
regions,
such
as
the
European
Economic
Area
(EEA),
United
Kingdom
(UK),
Switzerland,
and
Canada,
you
have
rights
that
allow
you
greater
access
to
and
control
over
your
personal
information.
You
may
review,
change,
or
terminate
your
account
at
any
time.
In
some
regions
(like
the
EEA,
UK,
Switzerland,
and
Canada),
you
have
certain
rights
under
applicable
data
protection
laws.
These
may
include
the
right
(i)
to
request
access
and
obtain
a
copy
of
your
personal
information,
(ii)
to
request
rectification
or
erasure;
(iii)
to
restrict
the
processing
of
your
personal
information;
(vi)
if
applicable,
to
data
portability;
and
(vii)
not
to
be
subject
to
automated
decision-making.
In
certain
circumstances,
you
may
also
have
the
right
to
object
to
the
processing
of
your
personal
information.
You
can
make
such
a
request
by
contacting
us
by
using
the
contact
details
provided
in
the
section
'HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?'
below.
We
will
consider
and
act
upon
any
request
in
accordance
with
applicable
data
protection
laws.
If
you
are
located
in
the
EEA
or
UK
and
you
believe
we
are
unlawfully
processing
your
personal
information,
you
also
have
the
right
to
complain
to
your
Member
State
data
protection
authority
orUK
data
protection
authority.
If
you
are
located
in
Switzerland,
you
may
contact
the
Federal
Data
Protection
and
Information
Commissioner.
Withdrawing
your
consent:
If
we
are
relying
on
your
consent
to
process
your
personal
information,
which
may
be
express
and/or
implied
consent
depending
on
the
applicable
law,
you
have
the
right
to
withdraw
your
consent
at
any
time.
You
can
withdraw
your
consent
at
any
time
by
contacting
us
by
using
the
contact
details
provided
in
the
section
'HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?'
below.
However,
please
note
that
this
will
not
affect
the
lawfulness
of
the
processing
before
its
withdrawal
nor,
when
applicable
law
allows,
will
it
affect
the
processing
of
your
personal
information
conducted
in
reliance
on
lawful
processing
grounds
other
than
consent.
Opting
out
of
marketing
and
promotional
communications:
You
can
unsubscribe
from
our
marketing
and
promotional
communications
at
any
time
by
clicking
on
the
unsubscribe
link
in
the
emails
that
we
send,
or
by
contacting
us
using
the
details
provided
in
the
section
'HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?'
below.
You
will
then
be
removed
from
the
marketing
lists.
However,
we
may
still
communicate
with
you
—
for
example,
to
send
you
service-related
messages
that
are
necessary
for
the
administration
and
use
of
your
account,
to
respond
to
service
requests,
or
for
other
non-marketing
purposes.
Account
Information
If
you
would
at
any
time
like
to
review
or
change
the
information
in
your
account
or
terminate
your
account,
you
can:
- Contact us using the contact information provided.
Upon
your
request
to
terminate
your
account,
we
will
deactivate
or
delete
your
account
and
information
from
our
active
databases.
However,
we
may
retain
some
information
in
our
files
to
prevent
fraud,
troubleshoot
problems,
assist
with
any
investigations,
enforce
our
legal
terms
and/or
comply
with
applicable
legal
requirements.
Cookies
and
similar
technologies:
Most
Web
browsers
are
set
to
accept
cookies
by
default.
If
you
prefer,
you
can
usually
choose
to
set
your
browser
to
remove
cookies
and
to
reject
cookies.
If
you
choose
to
remove
cookies
or
reject
cookies,
this
could
affect
certain
features
or
services
of
our
Services.
You
may
also
opt
out
of
interest-based
advertising
by
advertisers
on
our
Services.
For
further
information,
please
see
our
Cookie
Notice:
docion.com/policy/cookies.
If
you
have
questions
or
comments
about
your
privacy
rights,
you
may
email
us
at
[email protected].
12.
CONTROLS
FOR
DO-NOT-TRACK
FEATURES
Most
web
browsers
and
some
mobile
operating
systems
and
mobile
applications
include
a
Do-Not-Track
('DNT')
feature
or
setting
you
can
activate
to
signal
your
privacy
preference
not
to
have
data
about
your
online
browsing
activities
monitored
and
collected.
At
this
stage
no
uniform
technology
standard
for
recognising
and
implementing
DNT
signals
has
been
finalised.
As
such,
we
do
not
currently
respond
to
DNT
browser
signals
or
any
other
mechanism
that
automatically
communicates
your
choice
not
to
be
tracked
online.
If
a
standard
for
online
tracking
is
adopted
that
we
must
follow
in
the
future,
we
will
inform
you
about
that
practice
in
a
revised
version
of
this
privacy
notice.
13.
DO
CALIFORNIA
RESIDENTS
HAVE
SPECIFIC
PRIVACY
RIGHTS?
In
Short:Yes,
if
you
are
a
resident
of
California,
you
are
granted
specific
rights
regarding
access
to
your
personal
information.
California
Civil
Code
Section
1798.83,
also
known
as
the
'Shine
The
Light'
law,
permits
our
users
who
are
California
residents
to
request
and
obtain
from
us,
once
a
year
and
free
of
charge,
information
about
categories
of
personal
information
(if
any)
we
disclosed
to
third
parties
for
direct
marketing
purposes
and
the
names
and
addresses
of
all
third
parties
with
which
we
shared
personal
information
in
the
immediately
preceding
calendar
year.
If
you
are
a
California
resident
and
would
like
to
make
such
a
request,
please
submit
your
request
in
writing
to
us
using
the
contact
information
provided
below.
If
you
are
under
18
years
of
age,
reside
in
California,
and
have
a
registered
account
with
Services,
you
have
the
right
to
request
removal
of
unwanted
data
that
you
publicly
post
on
the
Services.
To
request
removal
of
such
data,
please
contact
us
using
the
contact
information
provided
below
and
include
the
email
address
associated
with
your
account
and
a
statement
that
you
reside
in
California.
We
will
make
sure
the
data
is
not
publicly
displayed
on
the
Services,
but
please
be
aware
that
the
data
may
not
be
completely
or
comprehensively
removed
from
all
our
systems
(e.g.
backups,
etc.).
CCPA
Privacy
Notice
The
California
Code
of
Regulations
defines
a
'resident'
as:
(1)
every
individual
who
is
in
the
State
of
California
for
other
than
a
temporary
or
transitory
purpose
and
(2)
every
individual
who
is
domiciled
in
the
State
of
California
who
is
outside
the
State
of
California
for
a
temporary
or
transitory
purpose
All
other
individuals
are
defined
as
'non-residents'.
If
this
definition
of
'resident'
applies
to
you,
we
must
adhere
to
certain
rights
and
obligations
regarding
your
personal
information.
What
categories
of
personal
information
do
we
collect?
We
have
collected
the
following
categories
of
personal
information
in
the
past
twelve
(12)
months:
| Category | Examples | Collected |
A.
Identifiers | Contact
details,
such
as
real
name,
alias,
postal
address,
telephone
or
mobile
contact
number,
unique
personal
identifier,
online
identifier,
Internet
Protocol
address,
email
address,
and
account
name | NO |
B.
Personal
information
categories
listed
in
the
California
Customer
Records
statute | Name,
contact
information,
education,
employment,
employment
history,
and
financial
information | NO |
C.
Protected
classification
characteristics
under
California
or
federal
law | Gender
and
date
of
birth | NO |
D.
Commercial
information | Transaction
information,
purchase
history,
financial
details,
and
payment
information | NO |
E.
Biometric
information | Fingerprints
and
voiceprints | NO |
F.
Internet
or
other
similar
network
activity | Browsing
history,
search
history,
online
behaviour,
interest
data,
and
interactions
with
our
and
other
websites,
applications,
systems,
and
advertisements | NO |
G.
Geolocation
data | Device
location | NO |
H.
Audio,
electronic,
visual,
thermal,
olfactory,
or
similar
information | Images
and
audio,
video
or
call
recordings
created
in
connection
with
our
business
activities | NO |
I.
Professional
or
employment-related
information | Business
contact
details
in
order
to
provide
you
our
Services
at
a
business
level
or
job
title,
work
history,
and
professional
qualifications
if
you
apply
for
a
job
with
us | NO |
J.
Education
Information | Student
records
and
directory
information | NO |
K.
Inferences
drawn
from
other
personal
information | Inferences
drawn
from
any
of
the
collected
personal
information
listed
above
to
create
a
profile
or
summary
about,
for
example,
an
individual’s
preferences
and
characteristics | NO |
| L. Sensitive Personal Information | NO |
We
may
also
collect
other
personal
information
outside
of
these
categories
through
instances
where
you
interact
with
us
in
person,
online,
or
by
phone
or
mail
in
the
context
of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How
do
we
use
and
share
your
personal
information?
More
information
about
our
data
collection
and
sharing
practices
can
be
found
in
this
privacy
notice
and
our
Cookie
Notice:
docion.com/policy/cookies.
You
may
contact
us
by
email
at[email protected],or
by
referring
to
the
contact
details
at
the
bottom
of
this
document.
If
you
are
using
an
authorised
agent
to
exercise
your
right
to
opt
out
we
may
deny
a
request
if
the
authorised
agent
does
not
submit
proof
that
they
have
been
validly
authorised
to
act
on
your
behalf.
Will
your
information
be
shared
with
anyone
else?
We
may
disclose
your
personal
information
with
our
service
providers
pursuant
to
a
written
contract
between
us
and
each
service
provider.
Each
service
provider
is
a
for-profit
entity
that
processes
the
information
on
our
behalf,
following
the
same
strict
privacy
protection
obligations
mandated
by
the
CCPA.
We
may
use
your
personal
information
for
our
own
business
purposes,
such
as
for
undertaking
internal
research
for
technological
development
and
demonstration.
This
is
not
considered
to
be
'selling'
of
your
personal
information.
We
have
not
disclosed,
sold,
or
shared
any
personal
information
to
third
parties
for
a
business
or
commercial
purpose
in
the
preceding
twelve
(12)
months.
We
will
not
sell
or
share
personal
information
in
the
future
belonging
to
website
visitors,
users,
and
other
consumers.
Your
rights
with
respect
to
your
personal
data
Right
to
request
deletion
of
the
data
—
Request
to
delete
You
can
ask
for
the
deletion
of
your
personal
information.
If
you
ask
us
to
delete
your
personal
information,
we
will
respect
your
request
and
delete
your
personal
information,
subject
to
certain
exceptions
provided
by
law,
such
as
(but
not
limited
to)
the
exercise
by
another
consumer
of
his
or
her
right
to
free
speech,
our
compliance
requirements
resulting
from
a
legal
obligation,
or
any
processing
that
may
be
required
to
protect
against
illegal
activities.
Right
to
be
informed
—
Request
to
know
Depending
on
the
circumstances,
you
have
a
right
to
know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell or share personal information to third parties;
- the categories of personal information that we sold, shared, or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
- the business or commercial purpose for collecting, selling, or sharing personal information; and
- the specific pieces of personal information we collected about you.
In
accordance
with
applicable
law,
we
are
not
obligated
to
provide
or
delete
consumer
information
that
is
de-identified
in
response
to
a
consumer
request
or
to
re-identify
individual
data
to
verify
a
consumer
request.
Right
to
Non-Discrimination
for
the
Exercise
of
a
Consumer’s
Privacy
Rights
We
will
not
discriminate
against
you
if
you
exercise
your
privacy
rights.
Right
to
Limit
Use
and
Disclosure
of
Sensitive
Personal
Information
We
do
not
process
consumer's
sensitive
personal
information.
Verification
process
Upon
receiving
your
request,
we
will
need
to
verify
your
identity
to
determine
you
are
the
same
person
about
whom
we
have
the
information
in
our
system.
These
verification
efforts
require
us
to
ask
you
to
provide
information
so
that
we
can
match
it
with
information
you
have
previously
provided
us.
For
instance,
depending
on
the
type
of
request
you
submit,
we
may
ask
you
to
provide
certain
information
so
that
we
can
match
the
information
you
provide
with
the
information
we
already
have
on
file,
or
we
may
contact
you
through
a
communication
method
(e.g.
phone
or
email)
that
you
have
previously
provided
to
us.
We
may
also
use
other
verification
methods
as
the
circumstances
dictate.
We
will
only
use
personal
information
provided
in
your
request
to
verify
your
identity
or
authority
to
make
the
request.
To
the
extent
possible,
we
will
avoid
requesting
additional
information
from
you
for
the
purposes
of
verification.
However,
if
we
cannot
verify
your
identity
from
the
information
already
maintained
by
us,
we
may
request
that
you
provide
additional
information
for
the
purposes
of
verifying
your
identity
and
for
security
or
fraud-prevention
purposes.
We
will
delete
such
additionally
provided
information
as
soon
as
we
finish
verifying
you.
Other
privacy
rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To
exercise
these
rights,
you
can
contact
usby
email
at
[email protected],or
by
referring
to
the
contact
details
at
the
bottom
of
this
document.
If
you
have
a
complaint
about
how
we
handle
your
data,
we
would
like
to
hear
from
you.
14.
DO
VIRGINIA
RESIDENTS
HAVE
SPECIFIC
PRIVACY
RIGHTS?
In
Short:Yes,
if
you
are
a
resident
of
Virginia,
you
may
be
granted
specific
rights
regarding
access
to
and
use
of
your
personal
information.
Virginia
CDPA
Privacy
Notice
Under
the
Virginia
Consumer
Data
Protection
Act
(CDPA):
'Consumer'
means
a
natural
person
who
is
a
resident
of
the
Commonwealth
acting
only
in
an
individual
or
household
context.
It
does
not
include
a
natural
person
acting
in
a
commercial
or
employment
context.
'Personal
data'
means
any
information
that
is
linked
or
reasonably
linkable
to
an
identified
or
identifiable
natural
person.
'Personal
data'
does
not
include
de-identified
data
or
publicly
available
information.
'Sale
of
personal
data'
means
the
exchange
of
personal
data
for
monetary
consideration.
If
this
definition
'consumer'
applies
to
you,
we
must
adhere
to
certain
rights
and
obligations
regarding
your
personal
data.
The
information
we
collect,
use,
and
disclose
about
you
will
vary
depending
on
how
you
interact
with
us
and
our
Services.
To
find
out
more,
please
visit
the
following
links:
Your
rights
with
respect
to
your
personal
data
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')
We
have
not
sold
any
personal
data
to
third
parties
for
business
or
commercial
purposes.
We
will
not
sell
personal
data
in
the
future
belonging
to
website
visitors,
users,
and
other
consumers.
Exercise
your
rights
provided
under
the
Virginia
CDPA
More
information
about
our
data
collection
and
sharing
practices
can
be
found
in
this
privacy
notice
and
our
Cookie
Notice:
docion.com/policy/cookies.
You
may
contact
us
by
email
at
[email protected],
by
visiting
[email protected],
or
by
referring
to
the
contact
details
at
the
bottom
of
this
document.
If
you
are
using
an
authorised
agent
to
exercise
your
rights,
we
may
deny
a
request
if
the
authorised
agent
does
not
submit
proof
that
they
have
been
validly
authorised
to
act
on
your
behalf.
Verification
process
We
may
request
that
you
provide
additional
information
reasonably
necessary
to
verify
you
and
your
consumer's
request.
If
you
submit
the
request
through
an
authorised
agent,
we
may
need
to
collect
additional
information
to
verify
your
identity
before
processing
your
request.
Upon
receiving
your
request,
we
will
respond
without
undue
delay,
but
in
all
cases,
within
forty-five
(45)
days
of
receipt.
The
response
period
may
be
extended
once
by
forty-five
(45)
additional
days
when
reasonably
necessary.
We
will
inform
you
of
any
such
extension
within
the
initial
45-day
response
period,
together
with
the
reason
for
the
extension.
Right
to
appeal
If
we
decline
to
take
action
regarding
your
request,
we
will
inform
you
of
our
decision
and
reasoning
behind
it.If
you
wish
to
appeal
our
decision,
please
email
us
at
[email protected].
Within
sixty
(60)
days
of
receipt
of
an
appeal,
we
will
inform
you
in
writing
of
any
action
taken
or
not
taken
in
response
to
the
appeal,
including
a
written
explanation
of
the
reasons
for
the
decisions.
If
your
appeal
if
denied,
you
may
contact
theAttorney
General
to
submit
a
complaint.
15.
DO
WE
MAKE
UPDATES
TO
THIS
NOTICE?
In
Short:
Yes,
we
will
update
this
notice
as
necessary
to
stay
compliant
with
relevant
laws.
We
may
update
this
privacy
notice
from
time
to
time.
The
updated
version
will
be
indicated
by
an
updated
'Revised'
date
and
the
updated
version
will
be
effective
as
soon
as
it
is
accessible.
If
we
make
material
changes
to
this
privacy
notice,
we
may
notify
you
either
by
prominently
posting
a
notice
of
such
changes
or
by
directly
sending
you
a
notification.
We
encourage
you
to
review
this
privacy
notice
frequently
to
be
informed
of
how
we
are
protecting
your
information.
16.
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
If
you
have
questions
or
comments
about
this
notice,
you
may
email
us
at
[email protected]
17.
HOW
CAN
YOU
REVIEW,
UPDATE,
OR
DELETE
THE
DATA
WE
COLLECT
FROM
YOU?
Based
on
the
applicable
laws
of
your
country,
you
may
have
the
right
to
request
access
to
the
personal
information
we
collect
from
you,
change
that
information,
or
delete
it.
To
request
to
review,
update,
or
delete
your
personal
information,
pleasevisit:
[email protected].
This
privacy
policy
was
created
using
Termly's
Privacy
Policy
Generator.