DUSFER PRIVACY POLICY

Version control: 1.0, last modified: August 31, 2020

FLAGMAN COMMERCE LTD together with its subsidiaries, affiliates, employees, officers, and directors as applicable (hereinafter the “Company” or all forms of pronoun “we”) is a company that provides certain services on the basis of and as described in the Dusfer Terms of Use (hereinafter the “Terms”), a current copy of which is available at https://dusfer.com/termsofuse/.

Note that this Privacy Policy is an integral part of the Terms and all terms shall be used in the same meanings as defined in the Terms, unless otherwise specified herein.

The Company respects the privacy of its users. We believe it is important for you to make informed decisions regarding the use of our Services based on your understanding of what information we collect through the use of our Services, what we do with such information, how we process it, with whom we share it, as well as your rights and choices regarding your information processed by us. For this purpose, we have drafted this Privacy Policy, which will further describe and detail our privacy practices while you use or otherwise interact with our Services.

Our Privacy Policy and our privacy practices are drafted in compliance with and adhere to the following acts:

and other applicable regulations, including national legislation (collectively hereinafter the “Applicable Legislation”).

1. SUBJECT

1.1. This Privacy Policy applies to our Services, including:

1.1.1. our Site as described in our Terms;

1.1.2. our App as described in our Terms.

1.2. Please note that this Privacy Policy applies solely to our privacy practices related to our Services, and it does not apply to the practices of third persons that the Company does not own or control or to people it does not employ or manage. Thus, we encourage you to review third-party privacy policies in order to be aware of data collection and use practices while using their services.

1.3. The term “Personal Information” shall be used interchangeably with the term “Personal Data” and shall be interpreted within the fullest scope established in the Applicable Legislation.

1.4. BY USING THE SERVICES, INCLUDING THE APP, YOU HEREBY AGREE TO THE TERMS OF THIS PRIVACY POLICY AND TO THE COLLECTION AND USE OF CERTAIN INFORMATION, AS DESCRIBED IN THIS PRIVACY POLICY. ANY USE OR CONTINUED USE OF THE SERVICES CONSTITUTES YOUR AGREEMENT AND CONSENT TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THE PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

2. ACCOUNT

2.1. In order to use certain Services, or parts of the Services, you may be prompted to create a designated Account. By creating an Account, you provide your consent to the collection, use and disclosure of the Personal Information as described in this Privacy Policy, and as needed. If at any time you do not want to be bound by this Privacy Policy, you shall deactivate your Account via settings or by emailing your request to: support@dusfer.com.

2.2. You represent and warrant that you are solely responsible for maintaining the confidentiality of your Account login credentials and security of any supplementary login methods, and liable for any and all activities made from your Account. You represent and warrant that you will not provide inaccurate, misleading or false information to the Company.

3. TYPES OF INFORMATION WE COLLECT

3.1. Our Services are created with “privacy by design” and “privacy by default” principles in mind. We undertake to empower you to the maximum possible extent in the matter of control over which information and to which extent you wish to provide to us, and how you want us to use it. Our Services designed in a way that allows you to provide your Personal Information in a minimum extent without ever needing to provide. Please, be advised that we do not sell your Personal Information and all your information is securely encrypted and the Company cannot access your Personal Information.

3.2. We may collect different categories of information from you as defined below, depending on the nature of your interaction with the Services, all as detailed below.

3.3. The first type of information is non-identifiable information that may be made available or gathered through your use of the Services; to clarify, we are not aware of your identity based on such information and it cannot be deduced from different types of such information (hereinafter “Non-Personal Information”). The Non-Personal Information that is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information such as: device brand, screen size, UDID, type of operating system, type of device, language preference, the time and date you access our Services, your actions within our Services (e.g., registration, pages viewed, etc.), the URLs from which you were directed to our Services, search queries within our Services, etc., and approximate geo-location limited to determining your country.

3.4. The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information includes information voluntarily provided by you as well as depersonalized identifiers as understood under GDPR (hereinafter the “Identifiers”). Note that the Identifiers even if separately do not allow to identify a specific person, nevertheless may be used together in order to achieve this effect, that is why they are considered Personal Information under some Applicable Legislation, that is why, the Company treats Identifiers as such and complies with applicable laws. With regards to our use of Identifiers and your ability to opt-out of such data collection, please see the table below, as well the “mobile opt out” provision below.

3.5. You are not required by law to provide us with Personal Information. You can always refuse to provide certain Personal Information; however, you acknowledge that such refusal may potentially prevent you from engaging in certain activities within Services.

3.6. In the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

3.7. INFORMATION COLLECTED VIA THE SITE

The table below details the information we collect from the users of the Site, why we collect it and how we use it:

Type of Information
How Do We Use It
In the event you contact us for support or other inquiries, either by sending us an email, or through the online form that may be available in the Site, or by other means of communications we make available, you will provide us with your email address and may provide us with your name.
We will use this information solely for the purpose of responding to your inquiries and providing you with the support you have requested.
In the event you wish to report us regarding Abusive Content or copyrights infringement you will be required to provide us with your name and email address and may be asked to provide your mailing address.
We will use this information solely for the purpose of communicating with you regarding your report.
In the event you are interested in joining our team, and wish to submit your CV to published job offers, you will be required to provide us with your name, email address, and CV. You may also be asked to provide us with your phone number, location (City), and LinkedIn profile. Your provision of Personal Information in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do NOT request, collect, or process sensitive Personal Information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.
Your provision of Personal Information in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do NOT request, collect, or process sensitive Personal Information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.
Identifiers
We may collect Identifiers from visitors of our Site. We will use it in order to fulfil our legitimate interests of operating, managing our Site, customizing and improving our Site and the content available therein.
We also collect certain technical Non-Personal Information (as detailed further) which relates to your use of the Site, the amount of time you spent viewing certain portions of the Site, etc.
We use this technical Non-Personal Information for the purpose of: (i) our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Site and Services and the way in which we offer them; (ii) enhancing your experience with the Services; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow, and detecting fraud, security or technical issues in connection with the Services; (iv) perform research, for analytical and statistical purposes, to improve our Services.

3.8. INFORMATION COLLECTED VIA THE APP

The table below details the information we collect from the users of the App, why we collect it and how we use it:

Type of Information
How Do We Use It
In order to use our App and related Services, you will be required to create the Account. During the registration flow you shall provide us with your phone number. Further during the registration process the you will be required to create a password; at which time you thereby represent and warrant that you are responsible for maintaining the confidentiality of your login credentials. After the registration is successful, you may, but not required to, provide us with certain information such as: first and last name, profile avatar, email, and username for your Account. You represent and warrant that you will not provide inaccurate, misleading or false information to the Company.
You may also link your password to Face ID or Touch ID and configure two-factor authentication. The information we will receive depends on your privacy settings with the network and you shall always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Services.
We will use this information for the purpose of performing our contract with you, provide you with the Services you have requested, and designate your account in order to display the applicable information in your Account. We will use your phone number only once in order to provide you with one-time code during the registration. After that it will be encrypted and stored at our servers. All information that you additionally voluntarily provide us within your Account, will be used by us in order to properly display your profile for other users, if you choose such option. However, in case you choose to hide your profile from the search or display only particular information pertaining to your Account, such as username only, all information will not be publicly accessible and will be for your disposal only. All such information related to your Account will be also encrypted and stored at our servers.
We are allowed to use your email address in order to send you needed information related to the Services and our business engagement (e.g., send you a welcome message, to notify you regarding any updates to our Services, changes in our requirements or privacy practices, and additional occasional communications related to the Services).
If you voluntarily subscribe to our newsletter you will be asked to provide us with your email address. You can unsubscribe at any time using the unsubscribe option within the body of the newsletter or by contacting customer support at support@dusfer.com.
We will use your email address in order to send you information related to our Services and to keep you up to date regarding new Services, updates and modification to them, related news, etc.
We also collect certain technical Non-Personal Information (as detailed herein) that relates to your use of the App including the amount of time you spent viewing certain portions of the Site, etc.
We use this technical Non-Personal Information for the purpose of: (i) our legitimate interests of operating, providing, maintaining, protecting, managing and customizing our App and Services and the way in which we offer them; (ii) enhancing your experience with the App; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow, and detecting fraud, security or technical issues in connection with the Services; (iv) perform research, and gather demographic information for analytical and statistical purposes, to improve our Services.
Approximate GEO location data
We will use this information solely in order to determine the User’s country and to apply relevant prices for the Services or offer enhances user experience, such as default language of the App and the advertisement in appropriate language.
Identifiers
We will use the Identifiers we collect for two purposes: (i) targeting the applicable advertising (for example, to enable ad frequency); and (ii) maintaining or internally analyzing the functioning of the App.
In any event, we use the Identifier solely for internal support purposes and/or in compliance with Applicable Legislation. We will not use any Identifiers in order to profile you or establish your behavior pattern for behavioral advertisement.
We also collect certain technical Non-Personal Information that may be contained in specifically created files, such as log-files. Such information includes information about data transfers, download/upload data speed, device model, version of the operating system, type of your hardware, IP address, device name, the time and date when you launched the App, and statistics on the use of the App. We will also collect Wi-Fi, 2G, 3G, 4G, 5G connectivity information related to your use of the App.
We use this technical Non-Personal Information for the purpose of: (i) our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Services and the way in which we offer them; (ii) enhancing your experience with the App; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow, and detecting fraud, security or technical issues in connection with the App; (iv) perform research, for analytical and statistical purposes, to improve our Services.

3.9. In case we need to collect additional Personal Information exceeding the scope detailed above, we will obtain your explicit consent prior to such collection, if required under Applicable Legislation.

3.10. We may use anonymized Personal Information in an aggregated, non-specific format for analytical purposes. Such data is anonymous and aggregated and we will not link statistical information to any Personal Information. We may share such statistical information with our partners without restriction. We also compile demographic data and usage-related information for a variety of uses in an aggregated or anonymized manner intended to remove or obscure any Personal Information which can identify any individual user.

3.11. At the time this Privacy Policy becomes effective, the Company does not qualify for the application of the CCPA. However, the Company still makes effort to comply with its provisions and fulfill disclosure obligations, namely:

3.11.1. we hereby disclose to the fullest extent, which information we collect and how we treat it;

3.11.2. you can request us to access and to delete any of your Personal Information anytime;

3.11.3. we do not discriminate against for exercising your privacy rights;

3.11.4. we refrain from processing Personal Information of minors, and will immediately obtain parental or guardian consent in case such need arises;

3.11.5. we do not sell your Personal Information, and if circumstances change, we will immediately enable you to opt out of the sale of your Personal Information via “Do Not Sell My Personal Information” option and we will not you request your opt-in consent for 12 (twelve) months after you opt out of such sale;

3.11.6. we enable you to submit data access requests and we undertake to expand them by adding a toll-free telephone number, if such need arises.

3.12. Please be advised that we may receive information associated with your payment information, such as billing address and transaction information but we do not directly store your payment information.

4. CHILDREN’S INFORMATION

4.1. We do not knowingly collect and process Personal Information of minors under 16 (sixteen) years of age or other age as prescribed by the Applicable Legislation, if higher, without parental consent, except as to the extent permitted under Applicable Legislation.

4.2. If we believe that we have collected and stored Personal Information from a child without the necessary parental consent or other legal basis to do so, we will delete the Personal Information provided as soon as feasibly possible and notify the parent or legal guardian. If you are aware that your child has provided us with its Personal Information not in accordance with the terms of this Privacy Policy or Applicable Legislation, please contact us at support@dusfer.com. In any case, the Company will follow the mechanism envisaged by COPPA for such occasions.

5. HOW WE COLLECT INFORMATION

5.1. Depending on the nature of your interaction with the Services, we may collect information as follows:

5.1.1. automatically, when the information transmitted from the device is collected automatically;

5.1.2. provided by you voluntarily, meaning, if and when you manually choose to provide us with information such as through a registration process, newsletter registration, communicating with us, etc.

5.2. In any case we do not knowingly collect any information from you or about you without your explicit prior consent.

5.3. While using our App, your Personal Information will be stored within the App in the memory of your device and at your discretion it may also be stored in iCloud, and/or on our servers. In case of iCloud, please refer to the relevant privacy practices in order to understand how your Personal Information is protected there. The measures taken by us in respect of protection of your Personal Information at our servers are described in this Privacy Policy.

5.4. In case any Applicable Legislation require us to the particular Personal Information within the geographic territory of a particular jurisdiction, and if our main servers are located outside this particular jurisdiction, we reserve the right to use our main servers for storage of copy of such Personal Information to the maximum permitted extent under such Applicable Legislation.

6. COOKIES

6.1. We may use cookies and web beacons (also known as action tags or single-pixel gifs), and other technologies (collectively "cookies") to provide us with data we can use to improve your experience and to know you better. Cookies are small text files sent from web servers that may be stored on your computer. Cookies enable us to capture how you arrived at our Site, when you return, which pages on our Site you visit, and to recognize that you are already logged on when we receive a page request from your browser.

6.2. We may use the following categories of cookies:

6.2.1. SECURITY

These cookies enable and support our security features, and to help us detect malicious activity.

6.2.2. PREFERENCES, FEATURES AND SERVICES

These cookies help us understand, which language you prefer and what your communications preferences are. They can help you fill out forms on our Sites more easily. They also provide you with features, insights, and customized content.

6.2.3. MARKETING

These cookies help us deliver marketing campaigns and track their performance (e.g., a user visited our Help Center and then made a purchase). Similarly, our partners may use cookies to provide us with information about your interactions with their services, but use of those third-party cookies would be subject to the service provider’s policies.

6.2.4. PERFORMANCE, ANALYTICS AND RESEARCH

These cookies help us learn how well our Sites and Services perform. We also use cookies to understand, improve, and research products, features, and services, including to create logs and record when you access our Sites and Services from different devices, such as your work computer or your mobile device.

6.3. Cookies are readable only by us and do not contain any Personal Information nor do they contain account or password information. We cannot and will not gather information about other sites you may have visited. We may share usage information about visitors to our Site with reputable advertising companies for the purpose of targeting our Internet banner advertisements. The information collected by the advertising company through the use of these pixel tags is not personally identifiable. We may also use third-party software to track and analyze usage and volume of statistical information, including page requests, form requests and click paths. The third party may use cookies to track behavior and may set cookies on behalf of the Company. Please be advised that each web browser has either incognito mode that prevents your browser from storing cookies after termination of the session or settings that allow you to disable cookies. By visiting our Site with your browser set to allow cookies, you consent to our use of cookies as described above. If you choose to block cookies, you may use our Site but some functions may not work as intended.

6.4. We do NOT use any Personal Information for profiling and/or behavioral advertisement. For more information, please see Section 3 of this Privacy Policy, which details what types of information are collected by us.

6.5. In addition, our Site through which you are able to access your Account may include cookies that might include your IP address, such as:

6.5.1. Google Analytics: the Google Analytics cookie is placed to track and analyze the use of our Services, for internal analytic purposes. To learn more about how Google uses data from our use of Google Analytics Cookies, we recommend that you review Google’s policies located at https://policies.google.com/technologies/partner-sites. We also encourage you to review Google Analytics currently available opt-outs for the web tool available at https://tools.google.com/dlpage/gaoptout/ and, https://adssettings.google.com/authenticated.

6.5.2. The Facebook pixel: a piece of code that lets us measure, optimize and build audiences for our advertising campaigns. The Facebook privacy policy can be found at https://www.facebook.com/privacy/explanation. We also encourage you to learn more about Facebook pixel at https://www.facebook.com/business/learn/facebook-ads-pixel.

6.5.3. VK pixel retargeting: this is JavaScript code that allows us to track all visitors from the site page on which it is installed: as soon as a person visits the page, the retargeting pixel automatically takes it into account. The VK privacy policy can be found at: https://vk.com/privacy. We also encourage you to learn more about VK pixel retargeting at https://vk.com/faq12142. With the help of a pixel, we are able to show ads to VKontakte users who visited our Site and performed certain actions there.

6.6. Our App through which you are able to access your Account may include cookies that might include your IP address, such as:

6.6.1. AppsFlyer SDK: this build-in Software Development Kit that allows for mobile marketing analytics and attribution. AppsFlyer privacy policy can be found at: https://www.appsflyer.com/privacy-policy/. We also encourage you to learn more about AppsFlyer here: https://www.appsflyer.com/.

7. DISCLOSURE OF INFORMATION

7.1. We do not disclose, share, sell, rent or otherwise distribute any of your Personal Information with or to any independent third parties unless as specified herein:

7.2. AUTHORIZED DISCLOSURES

We may disclose Personal Information to third parties when you consent to a particular disclosure. Please note that once we share your Personal Information with another third party, that information becomes subject to the other third party’s privacy practices.

7.3. BUSINESS TRANSFERS

We may transfer our databases containing Personal Information if we sell our business or any part of it. In that event, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.

7.4. LAW ENFORCEMENT RELATED DISCLOSURE

We may be required to share information, including Personal Information, collected if the information is required by law to prevent, investigate, or take action regarding illegal activities, situations involving potential threats to physical safety, rights, property or of any person, suspected fraud and violations of our terms and agreements and in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights or defend against legal claims.

7.5. PARTNERS, SERVICE PROVIDERS, AFFILIATES, AND SUBCONTRACTORS

We may disclose information, including Personal Information, we collect from and/or about you to our trusted affiliates, personnel, licensors, contractors, service providers, subcontractors and business partners who may use such information to help us provide you with the Services; for example, we may share the email addresses of users who have registered to our newsletter, in order to provide them with direct marketing services. We authorize these third-party service providers to use Personal Information only for the purpose of providing the specific services requested by us.

7.6. IDENTIFIERS

We may share Identifiers for the purpose of operating our business and providing the Services, meaning to serve the advertisements through our Services, as well as to calculate payments, detect fraud, security or technical issues in connection with the Services.

8. SECURITY

8.1. SYSTEM ACCESS CONTROL

Access to corporate systems is restricted and is based on procedures to ensure appropriate approvals are provided solely if needed. In addition, remote access and wireless computing capabilities are restricted and require that both user and system safeguards. The systems are also protected and solely authorized employees may access the systems by using a designated password and user name protections.

8.2. PHYSICAL ACCESS CONTROL

The Company ensures that physical access to its offices and serves is secure. The Company secures access to its offices and ensures that solely authorized persons have access such as employees and visitors. The offices are protected by an alarm system and the servers are located in protected facilities in which the physical access is controlled by professional security staff. We work with Amazon, as its main storage processor, therefore if you need more information, we recommend to review Amazon security policy. When the Personal Information is transferred to or from the applicable servers it is always done in a secure and encrypted manner, utilizing encryption protocol SHA-256. Further, the Company ensures that it entered binding processing agreements with each service provider. Nevertheless, you should be aware that there is no data that is transmitted over the Internet that can be guaranteed fully secure in transmission or safe from theft or illegal capture.

8.3. DATA ACCESS CONTROL

The access to the Personal Information is restricted solely to the employees that “need to know” and it is protected by passwords and user names. Access to the Personal Information is secured and is highly managed by access control policies. The Company uses high level security measures to ensure that the Personal Information will not be accessed, modified, copied, used, transferred, or deleted without specific authorization. The Company audits all accesses to the database and any authorized access is immediately reported and handled. Each employee is able to perform actions solely according to the permissions determined by the Company. Each access is logged and monitored, and any unauthorized access is automatically reported. Further, the Company has ongoing review of which employees’ have authorizations, to assess whether access is still required. Company revokes access immediately upon termination of employment. Authorized individuals can solely access Personal Information that is established in their individual profiles.

8.4. ORGANIZATIONAL AND OPERATIONAL SECURITY

The Company educates its employees, service providers, consultants, and contractors and raises awareness on risk and assessment with regards to any processing of Personal Information. Internal security testing is done on a regular basis. Our IT team ensures security of all hardware and software by installing anti-malware software on computers to protect against malicious use and malicious software as well as virus detection on endpoints, email attachment scanning, system compliance scans, information handling options for the data exporter based on data type, network security, and system and application vulnerability scanning, use secured email transfer, etc. It is the responsibility of the individuals across the Company to comply with these practices and standards.

8.5. TRANSFER CONTROL

The goal of transfer control is to ensure that Personal Information cannot be read, copied, modified or removed by unauthorized parties during the electronic transmission of these data or during their transport or storage in the applicable data center. Thus, any access to the Personal Information from beyond the Company network is solely possible by means of a secured VPN access. Further, any and all transfers of the data (either between the servers, from client side to server side and between Company’s designated partners) is secured (HTTPS) and encrypted. By transferring data, we also ensure to make it complaint with Applicable Legislation, namely, when transfer involves restricted transfers, we ensure that such transfer complies with a legally binding and enforceable instrument between public authorities or bodies, binding corporate rules, standard data protection clauses adopted by the European Commission, standard data protection clauses adopted by a supervisory authority and approved by the European Commission, an approved code of conduct together with binding and enforceable commitments of the receiver outside the EEA, certification under an approved certification mechanism together with binding and enforceable commitments of the receiver outside the EEA, or with contractual clauses authorized by a supervisory authority.

8.6. DATA RETENTION

We retain this collected Personal Information as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until individuals express a preference to opt-out or delete their Personal Information. Personal Information and raw data are all deleted as soon as possible or legally applicable. We may, at our sole discretion, delete Personal Information from or amend Personal Information in our systems without notice, once we deem it is no longer needed for such purposes.

8.7. JOB CONTROL

All our employees, partners, and applicable processors sign binding agreements that include applicable data provisions and data security obligations. As part of the employment process, employees undergo a screening and are provided with access to the database solely upon training to ensure he or she are well educated and responsible to handle the Personal Information. Employees are bound to comply with this Privacy Policy in addition to internal security policies and procedures and breaking or not complying with such shall result in disciplinary actions. To ensure the employees stay educated and up to date with applicable policies and legislation the Company holds annual compliance training which include data security education.

9. YOUR RIGHTS, CHOICES, AND CONTROL OF PERSONAL INFORMATION

9.1. Our users have a right to know what information we hold about them, in some cases, to have such information communicated to them. Our users may also ask for our confirmation as to whether or not we process their Personal Information. Subject to the limitations in Applicable Legislation, users may also be entitled to obtain from us the Personal Information they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right request to transmission of such Personal Information to another party. The principal rights that you have under Applicable Legislation in relation to your Personal Information are as follows:

9.1.1. THE RIGHT TO BE INFORMED

You are always entitled to know what your Personal Information we have and process.

9.1.2. THE RIGHT OF ACCESS

You may access and receive upon your written request Personal Information that is processed by the Company. If such request is excessive as well as repetitive the Company may refuse to provide you with copy of your Personal Information or request reasonable fee taking into account the administrative costs of preparing such copy.

9.1.3. THE RIGHT TO RECTIFICATION

You have the right to request to correct any information you believe is incomplete or inaccurate.

9.1.4. THE RIGHT TO ERASURE

You can anytime request the Company to delete all of your Personal Information.

9.1.5. THE RIGHT TO RESTRICT PROCESSING

You have the right to withdraw consent to process your Personal Information at any time by contacting us directly. Any such request shall be assessed by the Company whether such request does not contradict or could not contradict to other legal grounds of processing to which the Company is obliged.

9.1.6. THE RIGHT TO DATA PORTABILITY

You have the right to request that the Company transfer your Personal Information that we have collected to another organization, or directly to you. You have the right to receive your Personal Information in structured, commonly used and machine-readable format, as well as to transmit it to another controller. We are not obliged to protect your Personal Information that you choose to store or transfer outside our systems.

9.1.7. THE RIGHT TO OBJECT

You can in particular object to processing of your Personal Information in a certain manner. In particular, you may choose your Personal Information not to be subject to an automated decision-making in case we decide to apply one.

9.1.8. THE RIGHT TO COMPLAIN TO A SUPERVISORY AUTHORITY

You can anytime lodge a complaint with your supervisory data protection authority.

9.2. All aforementioned rights shall be exercised in good faith and on written request.

9.3. We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Information, depending on your relationship with us. If you wish to exercise any or all of the above rights, please contact us at: support@dusfer.com, and let us know that you wish to exercise your right of access and specify what Personal Information you would like to receive or delete, including if you wish to delete the Account completely. Where we are not able to provide you with the information you have requested, we will endeavor to explain the reasoning for this.

9.4. The reasonable time period for handling your request or complaint is 1 (one) month. Taking into account complexity and number of requests, we can extend this time for 2 (two) additional months. In case your request is manifestly unfounded or excessive, in particular because of their repetitive character, we may either:

9.4.1. charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or

9.4.2. refuse to act on your request.

9.5. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with Applicable Legislation.

9.6. In case the Applicable Legislation envisages rights broader than established herein, the relevant provisions of the Applicable Legislation shall prevail.

9.7. UNSUBSCRIBE FROM DIRECT MARKETING

You may revoke permission to receive promotional messages at any time by contacting customer support at support@dusfer.com or by following the unsubscribe link located at the bottom of each communication. Please note that even if you unsubscribe, we reserve the right to send you service-related communications, announcements and administrative messages.

9.8. OPT-OUT

You may easily opt out of certain automatic data collection, sharing process, and targeted advertising services related to our Service. Please note that even if you opt-out, you will still receive content and advertising. Opting-out simply means that the advertisements you do receive may not be contextual.

9.9. MOBILE OPT-OUT

You may limit the disclosure of certain information collected from your mobile device by adjusting the settings on your mobile device. You should review your device settings and instructions. Notwithstanding, we provide the following instructions solely for informational purposes as they might be revised by the device supplier:

Please read your device-specific information to learn how to opt-out:

9.10. INDUSTRY STANDARDS

You may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website and the Digital Advertising Alliance’s (“DAA”) website. You may opt out from such advertisers’ services through the following link: www.aboutads.info/choices.

Note that once you opt out, part of the Services provided by us might no longer be available and some features may not work if you revoke the data transfer.

If you have any additional complaints about your privacy rights, please contact our Data Protection Officer. Please note that you have the right at any time to contact your local data protection authority.

10. THIRD-PARTY SITES AND SERVICESc

10.1. This Privacy Policy applies solely to the information collected by the Company through the Services and does not apply to any other websites, applications or services.

10.2. Some portions of the Services, including advertisements, may involve linking to or using third-party services (hereinafter the “Third-Party Services”) such as various icons, shortcuts, applications or other means of access, and including third-party application distribution platforms, such as AppStore. Though we make best efforts to review such Services and ensure their suitability, we have no control over Third-Party Services and do not warrant or represent their secureness and compliance with Applicable Legislation. You agree and accept that you use such Third-Party Services at your own risk.

10.3. We cannot accept responsibility for the privacy practices of any such Third-Party Services and we are not responsible for any content made available by them.

10.4. The Company does not endorse any Third-Party Services and we urge you to exercise caution in using them and to carefully review their practices in relation to your privacy.

11. CHANGES TO THIS PRIVACY POLICY

11.1. This Privacy Policy may change from time to time. We will post the amended Privacy Policy and notify you by email in the event of substantial changes.

11.2. Amended terms will take effect immediately for new users, and 10 (ten) calendar days after they are posted for existing users.

11.3. You agree to accept posting of a revised Privacy Policy as an actual notice to you, that is why you shall review the Privacy Policy periodically to remain informed of any changes.

11.4. Your continued use of the Services following any changes to this Privacy Policy have been posted as of the “last modified” date indicated above, or, if applicable, after you have been notified, signifies your acceptance of those changes.

11.5. If you do not agree to the revised Privacy Policy, please refrain from using our Services and notify us by sending an email to: support@dusfer.com.

12. COMMENTS AND QUESTIONS

12.1. If you have any comments or questions about our Privacy Policy, please contact us at:
FLAGMAN COMMERCE LTD
Suite 3, 1st Floor, La Ciotat Building, Mont Fleuri, Mahe, Seychelles

12.2. You can also contact us via email at: support@dusfer.com stating “Privacy” in the subject line.

12.3. You can also refer your complaints to:

Data Protection Commission

21 Fitzwilliam Square
Dublin 2
D02 RD28
Ireland
Tel. +353 76 110 4800
email: info@dataprotection.ie
Website: http://www.dataprotection.ie/