PRIVACY POLICY

 

DEWBER PTE LTD (the “Company” or “we”) are committed to protecting and respecting your privacy.

 

This policy (together with our Terms of Use at: www.dewber.io/termsofuse sets out how we will process and use any personal data we collect from you, or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will handle it. 


It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

If the terms of this Privacy Policy are not acceptable to you, your only recourse is to leave our website immediately.

By visiting www.dewber.io you accept and consent to the practices described in this policy.

We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.

We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.

Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

The data controller is DEWBER PTE LTD

Information we collect from you

The law requires us to determine under which defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

We will collect and process the following data about you:

 

 

 Uses of your information

 

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

Disclosure of your information

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us [at email address or webpage]. However, if you do so, you may not be able to use our website or our services further.

You agree that we have the right to share your personal information with:


Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

  1. whether the same objective could be achieved through other means
  2. whether processing (or not processing) might cause you harm
  3. whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

  1. record-keeping for the proper and necessary administration of our Exchange
  2. responding to unsolicited communication from you to which we believe you would expect a response
  3. protecting and asserting the legal rights of any party
  4. insuring against or obtaining professional advice that is required to manage Exchange risk
  5. protecting your interests where we believe we have a duty to do so

Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Specific uses of information you provide to us

Information provided on the understanding that it will be shared with a third party

Our website may allow you to post information with a view to that information being read, copied, downloaded, or used by other people.

Examples include:

  1. posting a message in our forum
  2. tagging an image
  3. clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared.

We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at info@dewber.com

Data may be processed outside the European Union

Our websites are hosted on Digital Ocean within Europe

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly data obtained within the UK or any other country could be processed outside the European Union.

For example, some of the software our website uses may have been developed in India.

We It is our policy to use the following safeguards with respect to data transferred outside the European Union:

  1. the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
  2. the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union 
  3. we will comply with a code of conduct approved by a supervisory authority in the European Union.

 

 

Where we store your personal data

 

We engage commercial cloud storage providers to store the data that we collect from you. Therefore, your data may be transferred to and stored in different jurisdictions and may also be processed by staff operating within the various countries who work for us or for one of our contractors. By submitting your personal data, you agree to this transfer, storing or processing. We will take commercially reasonable steps to ensure that your data is handled securely and in accordance with this privacy policy and the relevant privacy laws.

 

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share the password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will take all commercially reasonable efforts to prevent unauthorized access.

 

Your rights

You have rights under the applicable Laws:

  1. to access your personal data
  2. to be provided with information about how your personal data is processed
  3. to have your personal data corrected
  4. to have your personal data erased in certain circumstances
  5. to object to or restrict how your personal data is processed
  6. to have your personal data transferred to yourself or to another business in certain circumstances.


7.2       You have the right to take any complaints about how we process your personal data to the competent Authorities of Jurisdiction.

For more details, please address any questions, comments and requests regarding our data processing practices to our Data Protection Manager:

RAJ AGRAWAL  


If you have any queries, questions or comments on the information contained in this Data Privacy Policy, kindly contact the Legal Team on [email protected] or [email protected]

Any access request will be subject to a fee of USD10.00 to meet our costs in providing you with details of the information we hold about you.

 

Other websites

 

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for your access of these websites. Please check their individual privacy policies for more information on how your personal data will be handled by these websites.

 

 About this Policy

This policy explains when and why we collect personal information about our members and instructors, how we use it and how we keep it secure and your rights in relation to it.

We may collect, use and store your personal data, as described in this Data Privacy Policy and as described when we collect data from you.

We reserve the right to amend this Data Privacy Policy from time to time without prior notice. You are advised to check our website www.cmdx.io (The Exchange) or our regularly for any amendments (but amendments will not be made retrospectively).

We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.gov.uk). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.

Log Data. Like many site operators, we collect information that your browser sends whenever you visit our Website ("Log Data"). The information collected in the Website’s Log Data may include, but is not limited to, your computer's Internet Protocol ("IP") address (with replaced last byte), browser type, browser version, the pages of the Website you visit, the time and date of your visit, the time spent on those pages and other statistics.

Changes to our privacy policy

 

We reserve the right to amend this privacy policy at any time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. You agree that it is your responsibility to check periodically for any updates or changes to our privacy policy.

 

Contact Information

 

We welcome any questions, comments and requests regarding this privacy policy. Please address them to [email protected] 


Responsibility Statement

The Exchange Legal Team provides generic legal advice for Exchange members, affiliated entities. The information contained in this Data Privacy Policy represents the Exchange’s interpretation of the law as at the date of this edition. The Exchange takes all reasonable care to ensure that the information contained in this Guidance is accurate and that any opinions, interpretations and guidance expressed have been carefully considered in the context in which they are expressed. However, before taking any action based on the contents of this Data Privacy Policy, readers are advised to confirm the up to date position and to take appropriate professional advice specific to their individual circumstances.