Privacy Statement

Welcome to our Privacy Policy!

Effective Date
September 9, 2019
For prior version, please click here.

If you are reading this Privacy Policy, it means that you have been redirected to this site from one of our many e-commerce or entertainment sites (the “Business Sites”) to ask for assistance from our Billing and/or Customer Support, or you are a simple visitor and want to submit a query about our products and/or services.

When you use these services, you will share some personal information with us. Because we want you to enjoy our services and trust us, please be assured that we are fully dedicated to the protection of your personal information.

Your privacy is important to us. This privacy Policy will explain how we collect, use and share your personal information, so that you can make informed decisions about the use of your data.

Please read this Privacy Policy carefully.

You can contact us if you have any questions about our privacy practices or about what we are doing with your personal information. We will be happy to assist you in any way we can.

1. WHO DECIDES “HOW” AND “WHY” YOUR PERSONAL DATA IS PROCESSED?

The “Data Controller” decides “how” and “why” your data is processed.

Duodecad IT Services Luxembourg S.à r.l. is the Data Controller for several Business Sites. Find details below:

Duodecad IT Services Luxembourg S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg
Registered under number: 171.358

2. WHAT PERSONAL DATA DO WE PROCESS?

We collect, use, share, transfer, and store different types of personal data as a result of your visit of and/or use of our services on our site.

The personal data we collect includes the following categories of data:

  1. 2.1. Personal data you give to us

    “Contact Us” form

    When you contact us via the “Contact Us” form, we require that you provide the following minimum information:

    • Your topic (why are you contacting us),
    • Your e-mail address,
    • Your comments and/or message.

    If you are a client of our Business Sites, you could also provide us with:

    • Your username,
    • Your full name.

    Providing this information about you is optional, however, we strongly advise you to do so, so that we can identify you faster and provide the support you need.

    “Transaction Inquiry” form

    When you contact us via the “Transaction Inquiry” form, we require that you provide the following minimum information:

    • Your e-mail address,
    • The date of your transaction,
    • The amount,
    • A comment (any information that will help us understand your issue/problem).

    You could also provide us with:

    • Your username,
    • Your full name,
    • The transaction number,
    • The type of credit card used (as the case may be),
    • The last 4 digits.

    Providing this information is optional, however, we strongly advise you to do so, so that we can identify the transaction concerned and provide the support you need.

    “Live Support” chat

    We process the message you share with us via the “Live Support” chat and any information you provide in it. However, if you send a message and do not provide any personal data on the chat, we cannot identify you directly and your name for the Billing and/or Customer Support will appear as “guest1”, “guest2”, etc.

    More generally, when you communicate with us in any other way, we will process whatever information you provide us with.

  2. 2.2. Personal Information from services use

    We collect certain information about you when you are using our services and navigate on our site.

    Usage information

    We collect information about your activity on our site including:

    • Which tool you used (“Contact Us”, “Transaction Inquiry” or “Live Support”),
    • When you used it.

    Content information

    We process any information you communicate and/or share with us on the site.

    We collect all communication data such as telephone conversations, chat logs, text messages, faxes and letters.

    Log data and device information

    We automatically collect log data and information from or about your computer, phone, or other devices you use to access our services and navigate our site. This includes:

    • your IP address;
    • pages viewed;
    • the hardware, software or internet browser you use;
    • information about your computer’s operating system, like application version;
    • your language settings;
    • identifiers associated with cookies or other technologies that may uniquely identify your device or browser.

    If you are using a mobile device, we might also collect:

    • data that identifies your mobile device;
    • device-specific settings and characteristics;
    • location details;
    • app crashes and other system activity.

    Information collected by cookies and other technologies

    Like many websites and applications, we use cookies and other technologies (such as web beacons, web storage, and unique advertising identifiers) to collect information about your activity, browser, and device.

    It is no longer permitted for web browsers to accept cookies by default. You must explicitly accept or reject Cookies on your browser or device. You may withdraw your consent to Cookies use through the settings of your browser or device.

3. WHY DO WE PROCESS YOUR PERSONAL DATA?

We use the information we collect for the following purposes:

  1. 3.1. Customer relationship management, customer support and communication with you

    We provide Customer and Billing Support service 24/7. Sharing your personal details with our Customer and Billing Support Team allows us to respond to any question you might have about our services.

    All your communications with our Customer and Billing Support and all information you provide in the course of such communications are stored and reviewed so that we may respond to your request.

    Some of the recorded communications with you are used for training purposes of our employees within the Customer and Billing Support so that we can ensure customer service excellence.

    If you are a client of our Business Sites, please be aware that when we receive a request or claim from you, our Customer and Billing Support team can access all information we have about you (provided and collected). By having this access, we ensure that our Customer and Billing Support team have everything they need to give you an appropriate and efficient response.

    Please note that the Customer and Billing Support may also communicate with you through emails or any other means, as appropriate.

    The use of your personal information is necessary to perform the contract that you have with us, notably to deliver appropriate customer services to you.

  2. 3.2. Ensure a safe and trustworthy environment

    Because we want to create and ensure a safe environment where you can peacefully enjoy our services, we use your personal data to detect and prevent fraud and other illegal activities on our site.

    If you are a client of our Business Sites, we also use your data to detect potential breaches of the terms & conditions of these sites.

    Finally, we use your personal information for security purposes and risk assessment.

    We process this information given our legitimate interest in ensuring compliance with the rules of our site and Business Sites, fraud detection, and prevention, as well as, information, system, network, and cybersecurity.

  3. 3.3. Correspondence

    When you use one of our services, we use your personal data to respond to your question/inquiry.

    The sending of messages is based on our legitimate interest.

  4. 3.4. Comply with any legal requirements and enforce our legal rights

    We may be legally required to process/keep your personal data. For example, we retain your transaction information to maintain legally required accounting records.

    We may also use your information to respond to requests of competent authorities or given our legitimate interest to establish, exercise or defend legal claims. We also use your data, if necessary, to investigate issues with the bank processing your payment or with a debt collector, in case of unpaid transactions, chargebacks or refunds.

    We may combine your information with information lawfully obtained from other third-party sources and use it for the above purposes.

4. HOW DO WE PROTECT AND HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We implement serious security measures, technical and organisational, to ensure the maximum protection possible of your personal information against unauthorized access, modification, disclosure or deletion.

We periodically test our IT systems, conduct sophisticated penetration tests and actively implement data loss prevention systems against leakage, theft and data breach to ensure that our site and entire IT infrastructure is regularly updated against the latest network security vulnerabilities.

We will retain your personal data for as long as we consider it necessary:

Provision of Services

To enable us to provide you with our services and for you to use them, including maintaining your member account opened on the Business Sites.

Legal Obligation Compliance

For example, we may keep some of your information for tax, legal reporting and auditing obligations. Please note that in accordance with Luxembourg legislation, financial information will be kept for a minimum period of 10 years.

Legitimate Interests and Business Conduct

Including:

  • Establishing, exercising or defending legal claims
  • Chargeback prevention
    We retain your chat logs and log data, device and usage information for a maximum period of 120 days from your last purchase on the site.
  • Fraud/illegal activity detection and prevention
    We blacklist all former usernames for a certain period; these usernames will not be available for new registrations during that time.
  • Enhancing safety

For example, if we suspend or close your account on our Business Sites due to fraud or illegal activities, we may retain certain information about you to prevent you from opening a new account in the future. Such information will also be kept available in case of ongoing judicial proceedings and/or investigations.

Security

As we have said, the protection of your information and our site from accidental or malicious loss and destruction is one of our top priorities.

Residual copies of some of your personal information will be kept on our backup systems for 30 days.

Some anonymized copies of your information (e.g. log records) may also remain in our database.

If you have a question about any specific retention periods of certain personal data, please contact us via the contact details provided in point 9 "HOW TO CONTACT US?"

5. WITH WHOM DO WE SHARE YOUR DATA?

We share a portion of your personal data with the following parties:

  1. 5.1. Commercial-purpose users of the Business Sites

    Depending on your question, we may share the information you provide with our service providers with whom you interact via our Business Sites. We will never share your information with these parties without a legitimate reason.

  2. 5.2. Entities of our company’s group

    We share your personal information with the following companies of our group based in Luxembourg, Hungary, and the US, as they are helping us deliver the services to you:

    • Jasmin IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
    • Docler Services S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
    • Docler IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
    • Docler SSC Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
    • Jasmin IP S.à r.l. Hungary Branch, Expo tér 5-7, H-1101, Budapest, Hungary;
    • Docler Media LLC, 10811 Washington Blvd, Culver City, CA 90232, USA;
    • Escalion S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg.
  3. 5.3. Business Sites Processors

    We use carefully selected and trusted third parties, who act as processors for our site.

    We ensure that they are bound by contractually binding obligations to process information we share with them in accordance with our instructions, this Privacy Policy, and all applicable data protection laws.

    As we constantly work on the development and enhancement of the technology to support our site, our third party processors may regularly change. Such entities mainly operate in the following areas: (a) business intelligence and analytics; (b) customer care; (c) fraud prevention.

  4. 5.4. Payment providers and financial institutions

    If your question concerns a payment/transaction issue, we may share your personal information with a third party bank or payment processor to administer and solve your problem.

    You may receive transactional emails from this party confirming the order, including dispatch, possible refunds, and follow-up invitations to leave feedback for this party.

    This Privacy Policy does not govern the processing of your personal information by these third parties if shared directly with them.

    Credit/Debit card

    If the transaction subject to your question relates to the payment method “Credit/Debit card”, your transaction issue will be solved by Escalion S.à r.l., which is part of our companies group and located in Luxembourg. You can find its privacy policy here.

    Chargeback

    When a chargeback is requested by you or by the credit card holder in certain circumstances, we have to share some information about you and your use of the services with the processing bank.

    Fraud Detection & Prevention

    We may share information with relevant financial institutions if we consider it strictly necessary for fraud detection and prevention purposes.

  5. 5.5. Law enforcement agencies or governmental authorities

    To the extent permitted by applicable laws, we may share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary to:

    • comply with our legal obligations,
    • respond to information requests for fraud investigations and alleged illegal activities,
    • enforce and administer our terms and conditions, and/or
    • protect our rights or defend ourselves against any claims.
  6. 5.6. Business transfers

    Your information may be transferred to another entity of our group (i.e. reorganization, restructuring, etc.) or third party (i.e. sale, merger and/or acquisition, etc.) resulting in part (more than 50%) or whole of the business (or related assets) being either directly or indirectly transferred under the control of the new owner.

    This would be the case providing the new owner operates in the same or similar line of business as ours and commits to comply with this Privacy Policy.

6. HOW DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA?

As we are a Luxembourg based company, we comply with the EU Data Protection Regulation, “GDPR” (click here to learn more), which provides for a high level of protection of your personal data.

In the course of the operation and exploitation of the site and the provision of services, your personal information may be transferred outside of the European Economic Area ("EEA") to our affiliated companies or to third parties data processors located in the US and other countries outside of where you live, for the purposes specified in this Privacy Policy.

If we transfer your personal data outside of the EEA, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we utilize the Standard Contractual Clauses approved by the European Commission that you can find here.

Please note that European citizen data will still be protected by the GDPR regardless of the processor’s location.

7. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

We did our best to explain what your rights are and how you can exercise them. If, despite our below explanations, you are still unsure about the actions you can take or the conditions of exercising your rights, do not worry, our Support Team will provide you with all the assistance you need.

You may also contact us, at any time, before exercising any of your rights, and we will reply to your request as quickly as possible.

Please note that under “Privacy Settings” in your account, you are able to exercise certain rights easily.

Our Support Team will provide you with information on actions taken within one month of the day of receipt of your request. Only in exceptional circumstances, when we face complex and a high number of requests, may we extend this period of response by up to two months.

Please note that rights may be exercised free of charge. However, unfounded or excessive requests, in particular, because of their repetitive character, will lead to the payment of a fee.

Please also understand that, because your privacy is so important for us, our Support Team may need to duly verify your identity and ask for additional information before executing your request.

  1. 7.1. Data access and data portability

    You have the right to access the personal information that we hold about you by requesting a copy of your personal data free of charge through the “Data Download” section in your account settings.

    Upon verification of your identity, your request will be sent to our Support Team.

    If we consider that your request is manifestly unfounded or excessive (for example, because you requested a copy of your data numerous times in a short period), we may refuse to act or charge a reasonable fee taking into account the administrative costs for providing you with the information.

    In certain cases, you are entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible). For this purpose, please contact us via the contact details provided in point 9 "HOW TO CONTACT US?"

  2. 7.2. Rectification of inaccurate or incomplete data

    You have the right to request that we correct any inaccuracies in your personal data.

    For this purpose, please contact us via the contact details provided in point 9 "HOW TO CONTACT US"

  3. 7.3. Data retention and erasure

    If you no longer want us to use your information, you can request that we erase your personal information and close your account. Requests for account cancellation or closure will be considered as a request for the erasure of your personal data.

    To close your account, please click “Forget My Data” in your profile’s privacy settings.

    Your request will be sent to our Support Team who will contact you to learn more about your request. However, if you face any difficulties, please contact us at any time.

    Please note that even if your request the erasure of your personal information, we will retain your personal data for as long as we consider it necessary for:

    Legal Obligation Compliance

    Legitimate Interests and Business Conduct

    Including:

    • Establishing, exercising or defending legal claims
    • Chargeback prevention
    • Fraud/illegal activity detection and prevention
    • Enhancing safety

    Security

    Some anonymized copies of your information (e.g. log records) may also remain in our database.

    For full information, please see point 4: “HOW DO WE PROTECT AND HOW LONG DO WE RETAIN YOUR PERSONAL DATA?”

  4. 7.4. Right to object

    • We process your data for a variety of reasons as explained in section 3 “WHY DO WE PROCESS YOUR PERSONAL DATA?”. Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will stop processing your personal data for these purposes.

      In specific situations, we may have to refuse the execution of your request. This would be the case where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

      Please keep in mind that objecting to the certain uses of your data may disable the use of your account.

    • Please note that you may, at any time, ask us to stop sending you marketing emails by opting-out in your account settings.

  5. 7.5. Right to restriction of processing

    You have the right to request that we hold your personal data in “limbo”, while other challenges are resolved.

    This is only possible in 4 cases:

    • If you contest the fact that the personal data we hold about you is accurate: in this case, the processing operations in relation to this data will be put on hold for the period during which this is verified.
    • You have objected to a processing activity based on (a) legitimate interest(s): in this case, you can require the processing operation to be put on hold while we verify the grounds for processing.
    • You consider your data to be processed unlawfully, but do not wish for your data to be immediately erased.
    • We have no further need for the data, but you require it to establish, exercise or defend legal claims.

    Despite your request, we may continue the processing of your personal data if we have to establish, exercise, or defend legal claims. We will notify you before lifting a restriction.

  6. 7.6. Right to lodge a complaint with a supervisory authority

    If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with the relevant supervisory authority.

8. CHANGES TO OUR PRIVACY POLICY

We may occasionally amend this Privacy Policy to reflect changes to our services and the way we handle your personal information or changes in the applicable laws.

If we make changes we consider important, we will let you know by placing a notice on the relevant site and/or contact you directly using other methods such as email.

To the extent permitted by applicable law, such changes will be applicable from the time they are published on our site unless we specify a date of entry into force. Your continued use of our site from that day on will be subject to the new Privacy Policy.

9. HOW TO CONTACT US?

If you have any comments or questions about this privacy policy or generally about our privacy practices, please log into your Business Site account and go to “Privacy Settings” where you can initiate either the download or erasure of your data, or ask any other questions related to your personal data.

If you are a simple visitor to this site, please contact us using the "Contact us" form, or send an e-mail to help@dditservices.com, and we will get back to you as soon as possible.

We are happy to inform you that we have an employee dedicated to ensuring your privacy, our Data Protection Officer. You can directly reach our Data Protection Officer via email at dpo@dditservices.com or by mail at the following address:

To the attention of the DPO
Duodecad IT Services Luxembourg S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg

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