Last Updated September 26 2016
For the purposes of the Data Protection Act 1998, the data controller is Dubsat Limited whose registered address is at 1 Primrose Street, London, EC2A 2EX.
Description of Users and Acceptance of Terms
The Information We Collect and/or Receive; The Purpose of Collection and Use
In the course of operating the Website and performing the Services, Dubsat will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.
1. Contact Information
When you contact us via the Contact Us page, or sign up to become a Subscriber, you will be asked to provide us with certain information which may include your name, address, phone number, and e-mail address (“Contact Information”). The Contact Information is used to provide the requested Services or information, and to contact Subscribers and Visitors for purposes of direct marketing of our current and future Services.
2. Billing Information.
When Subscribers sign up with us, they may be required to provide certain information in addition to the Contact Information noted above. Such information may include a debit card number, credit card number, expiration date, billing address, activation codes, and similar information (“Billing Information”). Billing Information is collected and processed by our third-party payment processor acting as our agent (See, Onward Transfers to Third Parties). We do not directly obtain or process any Billing Information.
In using the Platform, Subscribers may provide us Data (as defined in the Subscription and Services Agreement). We use the Data in accordance with the terms and conditions of the Subscription and Services Agreement.
4. Other Information.
In addition to the Contact Information, and the Data, we may collect or receive additional information (collectively, the “Other Information”). Such Other Information may include:
a. From Your Activity In an ongoing effort to improve the Website, the Platform and the Services, we automatically collect certain information when Visitors visit the Website and when Subscribers use the Services. This information consists of IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; Browser type and language; Referring and exit pages and URLs; Date and time; Platform usage, such as the amount of time spent on particular pages and other performance and usage data; and similar data concerning your use of the Website and the Services.
b. From Cookies
c. Third-Party Analytics
d. From You
We receive additional information that Visitors and Subscribers voluntarily provide to us. Such information may include product and service preferences, and other information that does not identify them personally.
In an ongoing effort to better understand our Visitors and Subscribers and the products and services of Dubsat and our promotional partners, we may analyze your information in anonymized and aggregate form in order to operate, maintain, manage, and improve the Website, the Platform, and/or such products and services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics in order to describe the Website, the Platform, and these products and services to current and prospective business partners and to other third parties for other lawful purposes.
Onward Transfer to Third Parties
Opt-In to Certain Onward Transfers
We will not transfer your personal information to third parties acting as controllers who may use your personal information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you without first providing you with information regarding the identity of such controller or the nature of such controller’s business, and obtaining your opt-in consent. When we provide this information regarding requested disclosure, we will include instructions for how to grant consent.
We will not disclose your sensitive personal information to any third party without first obtaining your opt-in consent. When we provide this information regarding requested disclosure, we will include instructions for how to grant consent.
In each instance, please allow us a reasonable time to process your response.
Disclosure to Public Authorities
We may be required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Opt-Out for Direct Marketing
You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to this email address: PRIVACY@DUBSAT.COM. Please allow us a reasonable time to process your request.
Access to personal information
Retention of personal information
Accessing and Modifying Communication Preferences
You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Dubsat marketing e-mail. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. Subscribers cannot opt out of receiving transactional e-mails related to their account with Dubsat.
How We Protect the Information
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. Unfortunately the transmission of information via the internet is not completely secure and we cannot guarantee its security. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
Important Notice to All Non-US Residents
Our servers are located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. Except in the case of data transfers under the EU-US Privacy Shield and the U.S.-Swiss Safe Harbor Framework, your decision to provide such data to us, or allow us to collect such data through our Website or the Services, constitutes your consent to this data transfer.
Important Notice For Residents of the European Economic Area
Dubsat is subject to the investigatory and enforcement powers of the Federal Trade Commission.
Important Notice for Residents of Switzerland
Dubsat has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
California and European Union Residents
307 Seventh Avenue
New York, New York 10001
In addition, Dubsat does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
If you are a resident of the European Union, you are entitled to withdraw consents to marketing contact at any time. To exercise this right, please send us an e-mail or letter to the contact points above.
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