PRIVACY POLICY
Last updated: 29 March 2024
1. DEFINITIONS
1.1. Brand – legal entity that creates its account on the DoReel platform on the Website;
1.2. Brand Representative – a representative of a legal entity that creates its account on the DoReel platform on the Website, acting in the name and interests of such legal entity (usually, an employee);
1.3. Client – Creators and/or Brands;
1.4. Company – DoReel LTD, registered office address 353 West 48th Street, New York, New York 10036, United States;
1.5. Creator – individual who creates his/her account on the DoReel platform;
1.6. Direct marketing – activities the purpose of which is to offer goods and services to persons by post, telephone or other direct means and / or to seek their opinion on goods or services offered;
1.7. EEA – European Economic Area;
1.8. GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing directive 95/46/EC (General Data Protection Regulation);
1.9. Personal data, data – any information relating to an identified or identifiable natural person (‘data subject’);
1.10. Privacy Policy – this privacy policy;
1.11. Supplier – a legal entity with which the Company has entered into an agreement on the provision of goods and/or services to the Company;
1.12. Supplier’s Representative – a representative of a legal entity with which the Company has entered into an agreement for the provision of goods and/or services to the Company, acting in the name and interests of such legal entity (usually, an employee);
1.13. Terms of Service – terms of service of the Company, which describe the terms of use of the DoReel platform on the Website, the procedure of providing the Company’s services, the rights and obligations of the Company, the Brand and the Creator [https://doreel.com/TOM];
1.14. Website – Company’s website at https://doreel.com.
2. THE PURPOSE OF THE PRIVACY POLICY
This Privacy Policy provides information on how the Company handles personal data when individuals use the Company’s DoReel platform, register on the DoReel platform on the Website, visit the Company’s Website as well as the Company’s social network accounts, provide inquiries, complaints, requests to the Company, and when the Company communicates with individuals in other cases.
This Privacy Policy provides information on the processing of data of the following categories of data subjects: (i) the Creator (Section 4.1); (ii) the Brand Representative (Section 4.2); (iii) the Website visitor (Section 4.3); (iv) the visitor of Company’s social network accounts (Section 4.4); (v) the person who submits inquiries, requests, complaints to the Company (Section 4.5); (vi) the Supplier’s Representative and/or the representative of another party (legal entity) to the contract concluded by the Company (Section 4.6); (vii) the Potential Client (its representative) (Section 4.7). Sections 1 – 3 and 5 – 8 of this Privacy Policy apply to all categories of data subjects.
We also inform you that changes in the functionality of the DoReel platform, Website, in technological solutions, as well as in the services provided by the Company can lead to changes in the Company’s data processing activities, therefore the Company may unilaterally renew and change this Privacy Policy. In view of this, we recommend the data subject to periodically review this Privacy Policy, taking notice of the last update, which is stated at the beginning of this Privacy Policy.
The Company ensures that any personal data specified in this Privacy Policy is handled in accordance with the highest standards of security and confidentiality, in strict compliance with GDPR requirements.
3. DATA CONTROLLER AND THE CONTACT DETAILS
The data controller – DoReel LTD, registered office address 353 West 48th Street, New York, New York 10036, United States. The contact details: e-mail: [email protected].
4. THE PROCESSING OF PERSONAL DATA, THE PURPOSES, LEGAL BASIS, SOURCES AND TERMS OF STORAGE OF THE DATA:
The data controller – DoReel LTD, registered office address 353 West 48th Street, New York, New York 10036, United States. The contact details: e-mail: [email protected].
4.1. The Creator
Categories of personal data processed
1. Data of registration on the DoReel platform, creation of account on the DoReel platform and of login to account:
– identifying information (name, surname, gender, country, date of birth (age));
– contact details (e-mail address, telephone number);
– account creation information (e-mail address, login password, photo);
– personal login settings when the Creator logs in the DoReel platform using Google, Apple, Facebook logins.
2. Data of using the DoReel platform:
– content created by the Creator (including, video material and/or photo, text);
– individual terms and conditions of the Creator’s agreement with the Company on the use of the DoReel platform (Terms of Service and other agreements (if any)) and details of their implementation (including, compensations, fees paid; Brand tasks applied by the Creator; content requirements of a specific Brand; accepted and fulfilled tasks of Brands; gift codes provided; products received);
– PayPal or other provided account number;
– address (only if product samples are sent to the Creator);
– clothing, footwear sizes (only if product samples are sent to the Creator);
– communication with the Creator regarding the use of the DoReel platform and provision of Company’s services (e.g., selected communication channel (telephone number, e-mail address), content of communication, time of communication).
3. Data that, according to legal acts, are necessary for the fulfillment of the Company’s tax obligations. Data required by law and tax administrator forms, including:
– identifying information (name, surname, personal identification code);
– compensations and fees paid by the Company to the Creator;
– taxpayer identification number (code), VAT payer code, individual activity certificate number, business certificate number;
– passport series and number, or identity card number, or permanent or temporary residence in the United States permit number;
– address of residence of a non-permanent resident of the United States.
Purposes and legal basis of data processing
The Company processes the personal data of the Creator listed above for the following purposes and based on the following legal basis:
1. purpose – to enable the Creator to register on the DoReel platform, create an account and join it, as well as to enable the Creator to use the DoReel platform, also to implement the mutual rights and obligations of the Company and the Creator established in the agreements concluded between the Company and the Creator (including, Terms of Services and other agreements (if any)). The legal basis for data processing for this purpose is the conclusion and performance of a contract with the Creator (Terms of Service and other agreements concluded between the Creator and the Company (if any)) (Article 6 (1) (b) of the GDPR). The contract with the Creator regarding the use of the DoReel platform is concluded by the Creator agreeing with the Terms of Service during the registration on the DoReel platform;
2. purpose – improvement and development of the DoReel platform, its functionalities and Company’s services. By analyzing the data, the Company gains a better understanding of its services, the use of the DoReel platform, which helps the Company to improve the DoReel platform and its services. The legal basis for data processing for this purpose is the legitimate interest of the Company to provide relevant, innovative, adapted, modern, secure services (Article 6 (1) (f) of the GDPR);
3. purpose – fulfillment of the Company’s legal obligations, including those related to the payment and administration of taxes, as well as protection of the Company’s legitimate interests. The data of the Creator may be used by the Company to fulfill the requirements imposed on the Company by legal acts, as well as mandatory instructions of the competent state authorities, and to defend Company’s rights and legitimate interests, including reputation, in courts and other competent authorities. The legal basis for data processing for this purpose is the legitimate interest of the Company to comply with the requirements of legal acts and to protect its violated rights and legitimate interests (Article 6 (1) (f) of the GDPR);
4. purpose – sending Company’s direct marketing offers to the Creator. The legal basis for data processing for this purpose is the legitimate interest of the Company to market its goods and services (Article 6 (1) (f) of the GDPR). The data is used for this purpose as long as the Creator expresses its disagreement with the Company for the use of the data for this purpose;
5. purpose – to ensure communication between the Company and the Creator. The legal basis for the processing of the Creator’s data for this purpose is the conclusion and performance of the agreement with the Creator (Article 6 (1) (b) of the GDPR) and the Company’s legitimate interest in ensuring customer service of appropriate quality (Article 6 (1) (f) of the GDPR);
6. purpose – Company’s advertising, marketing, public presentation (e.g., the use of Creator’s data in presentations of Company’s services, advertisements, public announcements on the Company’s website, social network accounts). The data of the Creator shall be processed for this purpose only with the separate consent of the Creator (Article 6 (1) (a) of the GDPR).
Data sources
The personal data of the Creator is obtained from the Creator himself/herself and generated for him/her using the DoReel platform. If the Creator connects to the DoReel platform using Google, Apple, Facebook logins, the Company will receive data from these companies about the Creator’s login settings.
Data storage period
The Creator’s data is stored for 10 years from the end of the agreement concluded between the Company and the Creator, i.e. since deleting (deactivating) Creator’s account on the DoReel platform.
This period of data retention may be extended if personal data are used or may be used as evidence or a source of information in a pre-trial or other investigation, including in civil, administrative or criminal proceedings, or in other cases provided for by law, or further storage and processing may be justified by Company’s legitimate interest or another legal basis. In such cases, personal data may be stored for as long as is necessary for those purposes for the processing and shall be destroyed immediately when data is no longer needed.
Data is a necessary condition for the provision of the Company’s services
The above-mentioned personal data of the Creator is necessary for the Company to be able to provide its services to the Creator in accordance with the Terms of Service and to comply with the related legal acts. Without providing this data, the Creator will not be able to register on the DoReel platform and/or to use it and receive related Company’s services.
If the Company’s personal data processing activities are not acceptable for the Creator, the Creator must not use the DoReel platform.
Acquaintance with Privacy Policy
By using the DoReel platform, the Creator acknowledges that he/she has carefully read and understood the Privacy Policy, and that the Creator accepts the processing of his/her personal data by the DoReel platform.
4.2. The Brand Representative
Categories of personal data processed
1. Contact information required to create the Brand’s account on the DoReel platform:
– telephone number of the Brand Representative;
– e-mail of the Brand Representative.
2. Data of the Brand Representative that is necessary or provided for the proper performance of the contract concluded between the Brand and the Company (Terms of Service and other agreements (if any)) and for the proper provision of Company’s services:
– identifying information (name, surname);
– workplace (Brand represented); position;
– contact details (phone number; e-mail address);
– signature;
– the data specified in the power of attorney (if such a document is provided);
– data related to the provision of services to the Brand or performance of the contract (e.g., content of e-mails, communications);
– name, surname under which the bank card with which the payment to the Company is made have been issued, as well as other data of such card (number, validity date, CVV code).
Purposes and legal basis of data processing
The Company processes the personal data of the Brand Representative listed above for the following purposes and based on the following legal basis:
1. purpose – to enable the Brand to register on the DoReel platform, create an account and join it, as well as to enable the Brand to use the DoReel platform, to implement the rights and obligations between the Company and the Brand, established in the Terms of Service and other contracts (if any). The legal basis for data processing for this purpose is the legitimate interest of the Company (Article 6 (1) (f) of the GDPR): interest – to know the data of a person responsible for concluding and executing the contract concluded with the Brand, to properly perform its contractual obligations to the Brand, and to require the Brand to properly perform its contractual obligations to the Company;
2. purpose – improvement and development of the DoReel platform, its functionalities, the Website and Company’s services. By analyzing the data, the Company gains a better understanding of its services, the use of DoReel platform, which helps the Company to improve the DoReel platform and its services. The legal basis for data processing for this purpose is the legitimate interest of the Company to provide relevant, innovative, adapted, modern, secure services (Article 6 (1) (f) of the GDPR);
3. purpose – fulfillment of the Company’s legal obligations, as well as protection of the Company’s legitimate interests. The data of the Brand Representative may be used by the Company to fulfill the requirements imposed on the Company by legal acts, as well as mandatory instructions of the competent state authorities, and to defend Company’s rights and legitimate interests, including reputation, in courts and other competent authorities. The legal basis for data processing for this purpose is the legitimate interest of the Company to comply with the requirements of legal acts and to protect its violated rights and legitimate interests (Article 6 (1) (f) of the GDPR);
4. purpose – to ensure communication between the Company and the Brand. The legal basis for the processing of the Brand Representative’s data for this purpose is the Company’s legitimate interest to ensure customer service of appropriate quality(Article 6 (1) (f) of the GDPR);
5. purpose – sending Company’s direct marketing offers to the Brand. The legal basis for data processing for this purpose is the legitimate interest of the Company to market its goods and services (Article 6 (1) (f) of the GDPR). The Company will consider that when registering on the DoReel platform and/or communicating with the Company, the Brand Representative provides the Company with a non-personal e-mail address, but with the Brand’s contact e-mail address. The data is used for this purpose as long as the Brand, acting through its representative, expresses to the Company its disagreement with the use of the data for this purpose.
Data sources
The data of the Brand Representative is obtained from the Brand Representative himself/herself and the Brand he/she represents, including in cases when the Company receives the data of the Brand Representative from his/her colleagues out-of-office message or other type of automatic reply, indicating the representative as a contact person, or the reply of a colleague with whom the Company has communicated to the Company’s e-mail, accompanied (cc) by the Brand Representative. Data can also be obtained from publicly available sources (e.g., Brand’s websites, LinkedIn accounts).
Data storage period
The Brand Representative’s data is stored for 10 years from the end of the agreement concluded between the Company and the Brand.
This period of data retention may be extended if personal data are used or may be used as evidence or a source of information in a pre-trial or other investigation, including in civil, administrative or criminal proceedings, or in other cases provided for by law, or further storage and processing may be justified by Company’s legitimate interest or another legal basis. In such cases, personal data may be stored for as long as is necessary for those purposes for the processing and shall be destroyed immediately when data is no longer needed.
Acquaintance with Privacy Policy
By registering the Brand’s account on the DoReel platform and submitting his/her personal data during this registration, the Brand Representative confirms that he/she has carefully read, understood this Privacy Policy and that the Company’s data processing activities are acceptable to the Brand Representative.
If the Brand Representative finds the Company’s personal data processing activities unacceptable, he/she must provide personalized data when registering a Brand’s account on the DoReel platform.
4.3. The Website visitor (Cookie policy)
Cookies
When a visitor visits the Website, to ensure the quality of the provided content and functionalities, cookies are being used. Cookies are small files which are stored on a user’s computer. They are designed to hold a modest amount of data specific to a particular client and website, and can be accessed either by the web server or the client computer. This allows the Company to recognize you as a Website visitor, save the information and help ensure a faster and more comfortable use of the Website. It also analyzes visitor’s behaviour helping improve the provided services. With the help of cookies, depending on the purpose and functionality of the cookie, data identifying the Website visitor, such as name, surname, e-mail, IP address may also be collected. So please read carefully the following list of cookies used on the Website, their functions and expiration dates.
Mandatory (technical) cookies
[List of mandatory (technical) cookies remains the same as in the original privacy policy]
Analytical cookies
[List of analytical cookies remains the same as in the original privacy policy]
Functional cookies
[List of functional cookies remains the same as in the original privacy policy]
Commercial cookies
[List of commercial cookies remains the same as in the original privacy policy]
Purposes and legal basis for the use of cookies
The purpose of mandatory (technical) cookies – to help ensure the proper functioning of the Website. These cookies are essential to run the Website successfully