Privacy Policy

Introduction 

Here, at davedealer.com (“Website”), we keep your security and privacy as our main priority and make sure that all your personal information is processed in a secure and lawful way. Here, you’ll find all the necessary information about our data processing policy, including why we need to process your data, which information exactly is collected, how long we are going to store it, who we will share it with, etc.

Who are we?

The Website is operated by NITAYA INVESTMENTS LIMITED (“The Company”, “We”, “Our”) which works under the laws of Cyprus. The registration number of the company is ΗΕ 384793, the registration address is Veroias, 3 Monovolikos 4, Kato Polemidia, 4150, Limassol, Cyprus. We are the Data Controller according to the Regulation 2016/679 of the European Union and the Council (“GDPR”).

1.1. How to contact us?

In case you have any additional questions about the data processing that can’t be answered by this Policy, or there is something you want to complain about, please contact us at pokiefilter.com, and we’ll reach back to you as soon as possible. 

What kinds of personal information do we collect, and when do we do it?

2.1 This information is automatically collected when you use the Website (“Automatically collected data”):

  • Information about the device you use. We track whether your device is computer or mobile, your device ID, operating system, the browser you use and its version, the time-zone you are in, and the language you have installed on your device. 
  • Information about your location, internet or mobile service provider, and your IP address. 
  • The source that led you to the Website. 
  • Data collected by cookies (please check our Cookie Policy to learn more).
  • Your behavioural pattern when using the Website, including the pages you visit, the number of times you visited the Website, and other related browsing information.
  • Information about your consent on receiving personalized marketing information and your agreement or disagreement with Cookies Policy, Privacy Policy, and other documents. 

2.2. This information is collected when you send us a direct email or a message using the Website interface, or when you subscribe to our weekly newsletter (“Message data”):

  • Your email
  • The subject of your request
  • Information about your newsletter subscription status. 

3. Which legal grounds allow us to use your data and how do we use it?

This is how the Company uses the data We collected and the legal grounds to do it: 

Purpose of data processing Legal Grounds
To protect the Website from illegal activities, frauds, and unlawful actions.  Data processing is necessary to pursue the legitimate interests of the Company.
To ensure that you get the information customized for your personal preferences, interests, and geography.  For example, we can provide you with the information in your language, or the information tailored for your interests and geography. Data processing is necessary to pursue the legitimate interests of the Company.
To provide you with the content customized for your personal preferences and interests.  Your Consent.
To conduct research and analysis for the development of new Website features. In this case, your data will be anonymised by removing any personal information. Thus, we’ll be able to identify how the audience uses the Website and introduce services that fit the preferences of our customers.  Your data will not be defined as personal information once it’s anonymised. Processing of such information doesn’t require your specific consent and is allowed by the law.
To comply with the requests of court, police, and other government agencies (if applicable).  Data processing is necessary to comply with the legal obligations of the Company.
To answer your messages or requests. Your Consent.
To record the processing activities. Data processing is necessary to comply with the legal obligations of the Company.
To subscribe you to our weekly newsletter. Your Consent.

4. Protection of children.

The use of the Website is not allowed for the users under the age of 18 or the legal gambling age in the jurisdiction of the particular user (“legal age”):

We do not collect or process the information of the users who didn’t reach the legal age. All the data of users identified as those under the legal age will be removed. Please contact us immediately if you find out that your child or ward uses the Website so that we can take measures.

By using the Website, each user certifies that he or she is of the legal age. The Company takes no responsibility for the use of the Websites by people under the legal age.

5. Who can we share your data with?

The data collected under the Policy can be shared with the following Parties: 

5.1 The affiliates, sub-contractors, and employees of the Company. The disclosure of your data, in this case, is based on the data transfer agreements, meaning these parties will only be allowed to process your information according to the Privacy Policy. The purpose of disclosure is to provide you with the full functionality of the Website.

5.2 Host, software, and service providers. Some of the Company infrastructure or the Website functions do not belong to the Company. For this reason, some of your data will be disclosed to the third parties.

5.3 Analytics. To understand the needs of our users and provide them with better services, we need to analyze the data collected.

Google Analytics

This is the web analytics service created by Google and aimed at tracking and reporting the website traffic. The data collected and analyzed by this service might be shared with other Google services. If you don’t want to allow Google Analytics to collect and use your data, you can install the Google Analytics Opt-out Browser Add-on here: https://tools.google.com/dlpage/gaoptout?hl=en-GB.

Hotjar

We use the Hotjar service to track the links our users click, the amount of time they spend on each page, and other user activities. Thus, we can better understand our customers and improve our services. Hotjar collects the users’ data such as device type, device screen size, IP address in anonymised form, country, chosen language, and browser information. This information is never used neither by Us nor Hotjar to identify individual customers. Please read Hotjar privacy policy to learn more here: https://www.hotjar.com/legal/policies/privacy

5.4 To police, court, and other governmental agencies upon their lawful requests.

6. How long do we store your data?

Your Message data and Automatically collected data will be stored as long as it’s needed to solve your requests and provide you with the Website services. If required by law, we can also store your data for a longer period of time.

As mentioned before, your data will be used after the anonymisation procedure is performed. This data will not contain any information that can be defined as “personal data” or that can be used to identify you.

7. Your rights

You have the number of rights that you can realize by sending an email to our Support Team:

The right to access your data. You have the right to get the confirmation that your personal data is being processed and obtain the copy of that data.

The right to correct your data. If you found out that some of your personal data is inaccurate, you can ask the Company to correct it.

The right to remove your data. If you don’t want to allow us to process your data  anymore, you can ask the Company to remove it. We will do it if we don’t need this data for the purposes specified above.

The right to object to the processing of your data. You have the right to object to the processing of your personal data for marketing purposes, if applicable. Besides, you have the right to object to the processing of your personal data on the grounds relating to your particular situation, if the grounds for data processing were necessary to pursue the legitimate interests of the Company.

The right to restrict the processing of your data. Please note that you have the right to restrict the processing of your data if:

a) the processing is unlawful and you prefer to restrict it instead of requesting the erasure;

b) you are not sure that the personal data processed is correct;

c) We don’t need your personal data to be processed anymore, but you need it to defend, establish, or exercise legal claims; d) you have objected to the processing of your data on the basis of your right to object pending to verify whether your legitimate grounds override legitimate grounds of the Company.

The right to withdraw consent to the processing of your data. You have the right to withdraw the previously given consent to data processing at any time. If you realize this right, we will stop processing your data starting from the day of the withdrawal. 

The right to transfer your data. You have the right to get your data from the Company in a machine-readable format and transfer it to another company.

Please note that some restrictions to these rights are applied: 

  • We may restrict or deny any of the rights on the legal grounds. In this case, we will specify the restriction or denial in our reply. 
  • We might request the verification of the identity of the requestor if we are not sure about it.

8. Complaint Information.

If there are any issues or complaints concerning your privacy, you can contact our Support Team at any time. Besides, you can register a complaint with the Office of the Commissioner of the for Personal Data Protection of the Republic of Cyprus here: www.dataprotection.gov.cy.

9. How is your data protected?

The following legal and technical methodology is used to protect your data: 

  • Legal methodology. We sign proper data transfer agreements with all the affiliates, employees, and subcontractors of the Company. Thus, all the third parties are obliged to comply with this Privacy Policy.
  • Technical methodology. We use proper encryption standards to protect your data. If any data breach happens, it would be impossible to access or identify your personal information.

10. Cookies.

We use cookies on the Website. It means that a small file is installed on your electronic device so that we can provide you with better experience and services by distinguishing you from other users. Please, follow our Cookie Policy to learn more.

11. Transfer of the data outside the European Union (For EEA residents).

Some parts of the Company are located outside the European Economic Area, where data protection legislation might be not as strict as the one in the European Union. Nevertheless, we take all the measures so that all the parts of our business group, including those located outside of the EU, process your personal data in compliance with The General Data Protection Regulation (EU) 2016/679 (simply, “GDPR”). By giving your consent to this Privacy Policy, you give us the right to transfer your data to these jurisdictions as well. You have the right to prohibit the data transfer at any time, though we can’t guarantee the access to some of the Website functions in this case.

12. Third-party Websites.

The Website might contain the links or banners leading to the third-party websites. The Company doesn’t take any responsibility for the content and anything that can happen during your use of those websites, so you visit them at your own risk. We recommend you to check the Privacy Policy of every third-party website you are about to use before consenting to any data processing.

13. Changes to this Policy.

This Privacy Policy might be changed. You’ll be informed about the changes by revising the date of the Policy. We recommend checking the Privacy Policy every time you access the Website. Please note that you agree to this Policy by continuing the use of the Website after the Policy is revised.

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