DMANY Privacy Policy

Dmany Development UG, a corporation registered in Germany under registration number [Registration in progress] and having its registered office at Im Mediapark 5, 50670 Cologne, Germany (referred to as “DMANY”, “We”, or “Our”), operates as both a consultancy firm and a software service provider. This document outlines the manner in which we handle the personal information you provide while using any DMANY Engagement Platform. We are responsible for and have authority over the personal information you share with us, determining how it is managed and utilized.

Kindly go through this Privacy Policy in detail to get a comprehensive understanding of how we treat and manage the personal data you entrust with us. When you navigate our website and engage with the Engagement Platform or any DMANY services, you acknowledge and consent to the terms described in this Policy.

This document provides clarity on how we gather, utilize, and share your information when you take advantage of DMANY’s offerings. Furthermore, it informs you of your rights concerning privacy and the protections offered by the law.

Our primary aim in using your personal data is to enhance the DMANY offerings available via the Platform. By interacting with the Engagement Platform and utilizing DMANY’s services, you consent to our collecting and using your information in alignment with this Privacy Policy.

Throughout this document, the term “DMANY Services” pertains to both the Engagement Platform and other related DMANY offerings.

1. Data Gathering

For those who sign up and utilize our DMANY Terms & Conditions, we necessitate specific contact details and relevant data for service provision. Depending on the selected services, to recognize users of the Engagement Platform and enhance our offerings, you might need to share:

• Personal details like names, birthdates, physical addresses, contact numbers, email IDs, government-issued IDs and their scans, photographs, IP addresses, digital wallet details, browser specifics, cookie and device identifiers, usage patterns, and geolocation.
• In certain scenarios, facial scans (“Biometric Data”) might also be collected. This Biometric Data is kept only until our identity verification and fraud prevention needs are met, or a shorter timeframe as mandated by the law, post which it’s permanently deleted.

If you suspect someone has shared your personal details with us without consent, and you wish it to be deleted from our records, kindly reach out to the provided contact email.

The aforementioned data will be stored as long as it’s essential to offer you DMANY Services, address any concerns you might present, or as long as the German law dictates.

Concerning each interaction on our Engagement Platform or while using DMANY Services, we may passively record:

• Details about your activity, inclusive of the complete URL pathways leading to, within, and from DMANY’s sites (along with timestamps);
• Products you viewed or searched for; metrics related to webpage interactions, like page response duration, errors during downloads, duration of page visits, interactions like scrolls or clicks, and the manner of exiting the page;
• Technical metrics such as the IP address linking your system to the internet, login details, browser specifics, timezone configurations, browser extensions, the operating system, and the device used;
• Any other details we may receive in the context of delivering DMANY Services;
• Publicly available data from connected social media accounts like Twitter / X (e.g., follower count, likes, profile details), Reddit (e.g., Karma, followers, display names), Telegram (e.g., user ID, username), and platforms like Github and Bitbucket (e.g., name, public repositories).

We may also acquire information from public databases. Furthermore, we collaborate with third-party entities (like business associates, technical sub-contractors, advertising networks, analytics service providers) and might receive details about you through them.

2. Your Data is Sourced Through Several Methods

Most of the data we gather is directly from your submissions to DMANY. Data collection and processing occur when you:

• Sign up online and use DMANY Services.
• Submit details for KYC (Know Your Customer) and AML (Anti-Money Laundering) verification, This data is processed by a trusted third-party service provider who own all necessary licenses.
• Voluntarily complete a Client survey or provide feedback on any of our message boards or via email.

In addition to the above, we might also obtain details about you from public records or through our Service Providers.

3. We Gather Your Data for Specific Purposes

The main reasons DMANY collects your details are so we and/or our partnering Clients can:

• Handle your requests and oversee your user profile.
• Share our newsletter via email, which users have the choice to decline anytime within the platform.
• Authenticate your identity in line with our Client’s KYC and AML standards.
• Address questions, remarks, feedback, or concerns to suggest you specific tasks/quests that you might be interested in.
• To manage our relationship with our users, which includes sending administrative information relating to DMANY Service and changes to our terms, conditions, and policies, and asking users to leave a review or take a survey;
• Evaluate user interactions with DMANY Services, maintain and refine the functionality and content of the Platform, bolster our customer relationships, and guide our marketing initiatives.
• Uphold and safeguard our business model and the Platform, deter illicit actions or misuse of the platform, and safeguard the integrity of our IT infrastructure.
• To comply with legal obligations and legal processes and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties, and recover debts due to us.

DMANY will relay this information to the specific Client associated with the platform you join to provide you with tailored community activities and rewards. 

Such data processing is vital for our contractual obligations with our Clients.

Obtaining your personal information aids us in furnishing a secure, seamless, and tailored experience. Predominantly, personal data aids in the creation, refinement, execution, and enhancement of our offerings, content, and promotional endeavors, as well as for risk mitigation and anti-deceit objectives.

The information amassed is crucial in delivering services as per our DMANY Terms & Conditions. We might also leverage this data to engage Clients and potential clients about their interest in our services, feedback on service improvements, and share news about DMANY or our associates.

Furthermore, you may receive newsletters or updates about the Services. Opting out is simple—by following the link in the email footer or by reaching out to us directly at [email protected].

We might also use Personal Data as delineated in the Terms & Conditions available at https://dmany.io/terms/ that define our relationship with both you and the Client. As mentioned, DMANY might track details like your IP, browser, device specifics, interactions on DMANY’s site, and generalized location data (termed as “usage data”). This data collection enables us to analyze the use of our website so as to improve user experience.

4. The Legal Grounds for Handling Your Data.

Upon registering on the Platform, you express your agreement to the handling of your personal data, as outlined in this Privacy Policy. You retain the privilege to retract this agreement at any subsequent time. You can instruct us to refrain from processing specific personal data or to provide access to it. It’s essential to be aware that, despite any retraction of your consent, any fees or costs incurred up until that point remain your responsibility. Moreover, retracting consent won’t compromise the legitimacy of any processing based on the agreement before its retraction.

In context with GDPR, the following are the circumstances under which your Personal Data might be handled:

• Consent: You’ve granted permission for processing Personal Data for designated purposes.
• Contractual Necessity: The handling of Personal Data is crucial for the fulfillment of a contract with you or our Clients, or for initial contractual responsibilities.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital Concerns: The processing is vital for safeguarding essential interests of you or another individual.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Regardless, we’re always available to elucidate the specific legal justification for processing, especially if the provision of personal details is a legal, contractual stipulation or a requisite to enter an agreement.

5. The Storage and Security of Your Data.

DMANY maintains the integrity of your platform data within a database hosted on Amazon Web Services. The communication internally between our servers (e.g. between application server and database) is handled via secure socket layer (“SSL”) to provide AE-256 encryption and all information between our servers and your browser is handled via SSL (up to 256-bit encryption, depending upon your browser), providing an industry-standard level of protection for data in-transit.

You should always make sure that your browser can validate the Website’s certificate.

All encrypted data is signed using a message authentication code (MAC) so that the underlying value cannot be modified once encrypted.

We also implement an advanced security method based on dynamic data and encoded session identifications and host the Services in a secure server environment using preventive, detective and corrective technology and processes to safeguard information from attackers. Finally, we require unique usernames and passwords that must be entered each time a Client logs on. These safeguards help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of data.

The sanctity of your personal details is pivotal. Sensitive data input into our registration or forms is encrypted using TLS technology. Additionally, any information entered within the platform post-login is also encrypted. 

For queries concerning our security protocols, feel free to reach out at [email protected].

Passwords that we provide or you select, enabling access to certain segments of our site and services, should remain confidential. We store passwords in an encrypted form using a one-directional hashing algorithm. It’s imperative that you safeguard your account credentials, bearing full responsibility for activities under your account. Password sharing is strongly discouraged.

It’s noteworthy that while we take comprehensive measures, data transmission over the internet has inherent vulnerabilities. While we strive to shield your data, its absolute security during transmission to our site cannot be assured. Upon receiving your data, rigorous protocols and protective measures are in place to deter unauthorized infiltrations. In the event we become aware that your data has been compromised or stolen, we will notify you as soon as reasonably possible to allow you to take appropriate measures.

Except as mentioned in this Privacy Policy or when compelled by law, we will not disseminate or share any of your personal details. We may, however, disclose information to uphold our rights or adhere to legal processes, including court orders or judicial proceedings.

6. Duration of Data Storage

We’ll retain your personal data as long as it’s crucial for delivering the DMANY Services on our platform, addressing any concerns you might express, or as demanded by relevant laws, especially concerning legal obligations like tax-related matters. Following the termination of your service subscription, we’ve adopted guidelines to erase data from your account. Any personal data that’s outlived its retention span or is no longer relevant for its processing purpose is either deleted, annihilated, blocked, or made anonymous. We’ll store your personal details for a timeframe that’s justifiably essential for the purposes delineated in this Privacy Policy, while we possess a legitimate commercial reason to do so, or as prescribed by regulations. When you choose to accept marketing messages from us, we preserve data regarding your marketing choices until you decide to unsubscribe, following our standard practices. The suitable retention duration for your personal details will be assessed based on its volume, type, and sensitivity, potential risks from unwarranted use or revelation, our processing objectives, and legal stipulations.

7. Divulging Your Personal Data to Third Parties

Your personal details might be disclosed or shared with third parties under the following circumstances:

• With tools like Google Analytics to assess our site traffic.
• During discussions or actual mergers, asset sales, company financings, or acquisitions.
• If legally compelled to reveal or distribute your details.
• Sharing with Service Providers for the purpose of validating your identity.
• To keep you informed about service news, updates, promotional offers, and other relevant information from us, our associates, or external parties.
• To enforce our DMANY Terms & Conditions or related contracts.
• Sharing with our affiliated entities, ensuring they abide by this Privacy Policy. This includes parent entities, subsidiaries, or entities that fall under our operational umbrella.
• We may share your information with our business partners to offer you certain products, services or promotions;
• When you share personal information or otherwise interact in the public areas of the Platform with other users, such information may be viewed by all users and may be publicly distributed outside;
• We may disclose your personal information for any other purpose with your consent.
• or to protect the rights, property, or safety of DMANY, our Clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction; or
• as otherwise outlined in this Privacy Policy.

Additionally, your data might be accessible to our external data handlers and our commercial collaborators, including those assisting with technical services, payments, deliveries, promotional networks, data analysis, and information search. However, without your prior agreement, we will not deliberately share your personal data with a third party.

8. Understanding Your Data Protection Privileges

At DMANY, it’s crucial that you’re well-informed about your data protection entitlements. As a user, you can expect:

Your rights Under EU and UK GDPR:

• You can solicit copies of your personal details from DMANY. There might be a fee for this if the demand is manifestly groundless, or excessive, or if additional copies are asked after an initial request.
• If you find inaccuracies in the data DMANY has, you can request corrections or completion of incomplete details.
• You may request DMANY to delete your data, as long as this doesn’t contradict the Terms & Conditions.
• You can ask DMANY to limit how we handle your data, as long as it adheres to the Terms & Conditions.
• You can challenge DMANY’s data processing, especially when the GDPR cites specific reasons for such objections.
• You can request DMANY to transfer your information to another entity or directly to you, in compliance with GDPR conditions.
• You’re free to retract any consent regarding your data usage. This might impact your access to DMANY’s platform and services.

For specific purposes, or if you’d like to access your information, get in touch at the stated email. However, retracting your data processing consent might incur certain fees. Should you forward a request, we’ll revert within a month. If you want to exercise these privileges, email us at: [email protected]. If you feel your rights aren’t being observed, contact the regulator. For data concerns or if you suspect someone has shared your information without permission, reach our data protection team at: [email protected].

To practice these rights, reach out, but be prepared to validate your identity. We aim to address your concerns swiftly. For any data protection complaints, if you’re in the UK or EEA, connect with the local data protection body.

Special Provisions for Californians (CCPA):

Our handling of Californian consumer data aligns with the CCPA. We’ve described the data collection, usage, and sharing procedures in the sections mentioned. As a California resident, you have certain CCPA-specific choices:

• Right to Know: Ask about categories, specifics, origins, reasons, and third-party sharing of your data.
• Right to Delete: You can prompt us to erase your data, with some legal restrictions.
• Right Against Sale: You can oppose any potential “sale” of your data.
• No Discrimination: Exercising these rights won’t lead to unfair treatment.

To practice any above rights, communicate with our privacy team at: [email protected].

Concerning Minors:

DMANY doesn’t target or intentionally collect data from individuals under 18. If you’re a guardian and discover your minor has shared data with us, please alert us. If we identify data from minors without parent consent, we’ll take actions to purge such information from our systems.

9. How we use Cookies

Cookies are small text files stored on your device that track online activity and user interactions. Our website automatically gathers information using cookies or similar technologies when you access it. 

DMANY utilizes cookies to elevate your user experience by:

• Ensuring you remain logged in
• Gauging your interaction with our website
• Retaining your platform settings.

Different cookies serve different functions. At DMANY, we use Functionality cookies to remember and cater to your preferences. This might encompass your chosen language or regional location. The first-party cookies we apply include:

• Analytics cookie;
• CSRF token for protection against attacks;
• Tour cookie;
• Session ID cookie;
• Browser local storage cookie.

While you can adjust your browser settings to decline cookies, doing so might impact the optimal functionality of certain website features. You’ll be presented with a one-time consent option that you can decline if desired.

10. Privacy on External Links

Occasionally, DMANY’s website and Platform might link to third-party sites or services for identity verification. If you navigate to these links, bear in mind that they operate under their individual privacy policies, which might also pertain to other DMANY offerings. We’re not responsible for their content or policies. Always review their terms before sharing personal data.

11. Revisions to Our Privacy Policy

DMANY may periodically revisit and modify its privacy policy, with updates reflected on this page. The most recent update was on October 5th, 2023. Should significant changes occur, we’ll notify you via email or a noticeable alert on our platform. It’s recommended to routinely check this policy for alterations. Amendments become binding once posted here.

12. Reach Out to Us

For queries regarding our privacy practices, data we possess about you, or if you wish to enact a data protection right, we’re here to assist. Connect with us at: [email protected].