Privacy Policy

Our Beginning

We – referred to as 'We' or 'Our' – are committed to protecting your personal data and your privacy.

This privacy policy is designed to explain how we collect, store, process, and use the information you provide in connection with the website Dorivo (hereinafter "Website").

We are committed to the following principles:

Transparency in collecting and processing your personal data:

We ensure you are always well-informed so you can make conscious choices about how your data is used on the website or when you interact with third-party platforms. We use various methods to provide you with accurate and timely information about the processing of your data.

If we need to give you specific information, we ensure it is delivered at the right time and place.

We are also available to answer questions or provide clarifications, within the applicable legal framework. You can reach us via email: [email protected]

Processing personal data only for the purposes stated in this policy:

We may process your information to make the website available, connect you to third-party trading platforms ("Services"), improve user experience, develop the platform, protect our rights, carry out administrative processes, and fulfil legal requirements.

We also process information to better understand your needs and preferences.

Resources to uphold your rights:

We dedicate significant resources to ensure you can exercise your rights as a data subject. You may at any time request access to, rectification, erasure, or restriction of your information, or request its portability. We will respond in accordance with applicable law.

Protection of your personal data:

While we cannot guarantee absolute security, we employ modern security methods and measures to protect your information and will continue to improve these.

Our Full Privacy Policy

1. Scope

This policy describes the types of data we collect, how we process them, share them with third parties, and the security measures we apply.

"Personal data" means any information relating to an identified or identifiable natural person. "Processing" means any operation such as collection, storage, use, sharing, alteration, or erasure.

Our Services are intended for a general audience and are not directed at individuals under 18. We do not knowingly collect information from minors. If we discover such information has been recorded, we will delete it promptly.

2. When do we collect information?

We collect data when you use our Services, visit the website, or interact with our channels. Some information you provide directly; other information is collected automatically through analysis of your activity or via third-party partners.

3. No obligation to provide data – but consequences

You are not required to provide us with information. However, without certain data, we may not be able to offer you all our Services or provide you with full access to the website.

4. What types of information do we collect?

This may include activity logs, IP addresses, timestamps, language, browser type, device information, and error logs. Some of this may not identify you directly and is therefore not considered personal data.

Information you provide directly: name, phone number, email address when you contact us or use the platform.

5. Purposes of processing and legal basis

Dorivo processes information only when we have a legal basis, for example, to provide Services, improve experience, protect your data, or fulfil legal obligations.

• You have consented to the processing of your personal data for specific purposes. This applies when you consciously share information via the website so we can forward it to a third-party trading platform.
• Processing is necessary for the legitimate interests pursued by Dorivo or a third party. For example, this may include improving our Services or handling legal claims.
• Processing is necessary for compliance with a legal obligation to which Dorivo is subject.

If you would like further explanation on how processing your personal data serves the legitimate interests of Dorivo or a third party, you can contact us via email at any time.

Below is an overview of why we may process your information, along with the legal bases:

6. Transfer of personal data to third parties

Dorivo may share your information with third-party providers who assist with storage, hosting, IP information, user experience analysis, research, and other technical or diagnostic services.

If you request it, we may also transfer certain information to third-party trading platforms. In such cases, they will process the information in accordance with their own privacy policies. We may share information with multiple trading platforms.

Dorivo may also share information with affiliated companies and business partners who contribute to improving the quality of our Services.

We may disclose information to public authorities if necessary to protect our or third parties' interests, rights, or assets, including in connection with legal proceedings.

Information may also be shared with potential buyers, investors, or lenders in connection with a merger, acquisition, reorganisation, or bankruptcy proceedings.

7. Cookies and third-party services

We use certain third-party services, such as analytics and advertising providers. These may use cookies or similar technologies, governed by their own policies.

A cookie is a small text file stored on your device when you visit the website. It may collect information about usage patterns, preferences, and technical data, and is used to enhance your experience, remember settings, and deliver more relevant content.

We may use both session cookies (which are deleted when you close your browser) and persistent cookies (which remain on your device until they expire or are manually deleted).

Types of cookies:

Blocking and deleting cookies

You can change your browser settings to block or delete cookies. Here are links to instructions for the most commonly used browsers:

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that some features on the website may stop working if you block cookies.

NOTE ON DO NOT TRACK

This service currently does not respond to 'Do Not Track' signals.

8. Storage of personal data

Dorivo will store your information for as long as necessary for the purposes described in this policy, or as required by law, regulation, or authority.

If you have consented, we may share information with third-party trading platforms for up to 12 months, with the possibility of extension upon renewed consent.

We regularly review stored information to ensure it is not kept longer than necessary.

9. Transfer of personal data to third countries or international organisations

Your personal data may be transferred to a third country (outside Australia) or to international organisations. In such cases, Dorivo will implement necessary safeguards to ensure the information is protected and that you retain your rights and effective legal remedies.

If you are resident in Australia, such protective measures will apply if one of the following criteria is met:

• The transfer is to a third country or international organisation that the relevant authority has recognised as having an adequate level of data protection.
• The transfer is carried out based on a legally binding and enforceable agreement between public authorities or bodies.
• The transfer is based on standard data protection clauses adopted by the relevant authority. These clauses are available on the authority's website.

If you would like more information about the safeguards we use when transferring personal data, you can contact us via email: [email protected]

10. Protection of personal data

We use technical and organisational security measures to protect personal data against unauthorised access, alteration, loss, or destruction. These measures are adapted to the risk associated with the processing.

We cannot guarantee absolute security for data transmission over the internet. Dorivo disclaims liability for indirect or incidental damages that may arise from data loss or unauthorised access beyond our reasonable control.

In some cases, we may be legally obliged to share information with public authorities. In such instances, our level of control over the protection of the information may be limited.

11. Links to third-party websites

The website may contain links to external websites or applications operated by third parties. Dorivo has no control over these and is not responsible for their processing of personal data. We recommend you always read their privacy policies before providing any information.

12. Your rights regarding personal data

You have the right to request access to the information we process about you, to request correction of errors, to request deletion of data that is no longer necessary, and to restrict or withdraw consent for specific processing activities.

Right of access

You have the right to obtain confirmation as to whether Dorivo processes personal data concerning you. If we do, you have the right to access that data and information about: purposes, categories of data, recipients (including in third countries), storage period, your rights, the right to lodge a complaint, and the safeguards implemented for transfers.

You may receive a copy of the data being processed. If you request further copies, we may charge a reasonable fee. If the request is made electronically, you will normally receive the data in a commonly used electronic format.

The right of access shall not adversely affect the rights and freedoms of others. If this occurs, we may restrict access or decline the request.

Right to rectification

You may request that Dorivo correct inaccurate or incomplete data concerning you. If necessary, you may supplement it with a supplementary statement.

Right to erasure ('right to be forgotten')

You have the right to request erasure of your data when it is no longer necessary for the purposes for which it was collected, when you withdraw consent, or when the processing is unlawful. We will respond in accordance with applicable law.

Right to erasure ('right to be forgotten')

This right applies if: (a) the personal data is no longer necessary for the purpose it was collected; (b) you withdraw consent and there is no other legal basis; (c) you object to processing based on our or a third party's legitimate interests, and there are no overriding legitimate grounds; (d) you object to processing for direct marketing; (e) the data has been unlawfully processed; or (f) the data must be erased to comply with a legal obligation under Australian law.

The right does not apply if the processing is necessary (a) for compliance with a legal obligation, or (b) for the establishment, exercise, or defence of legal claims.

Right to restriction of processing

You may request that we restrict the processing of your data if: (a) you contest the accuracy, for a period enabling us to verify; (b) the processing is unlawful, but you oppose erasure and request restriction instead; (c) we no longer need the data, but you require them for legal claims; (d) you have objected to processing, pending verification of our legitimate grounds; (e) the data is processed for direct marketing, including profiling.

If processing is restricted, the data may only be used with your consent, for legal claims, to protect the rights of others, or for reasons of important public interest.

Right to data portability

You have the right to receive the personal data you have provided to us, in a structured, commonly used, and machine-readable format. You may also request that we transmit the data directly to another controller, where technically feasible, and where the processing is based on consent or contract and carried out by automated means.

Right to withdraw consent

You may withdraw your consent to processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to object

You may object to the processing of your data when the processing is based on legitimate interests. This also applies to profiling. We will then cease processing, unless we demonstrate compelling legitimate grounds overriding your interests and rights, or if the processing is necessary for legal claims.

You may also object at any time to processing of your data for direct marketing, including profiling related to such marketing.

Right to lodge a complaint with a supervisory authority

You may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) or another supervisory authority if you believe the processing of your personal data infringes applicable privacy laws.

We will respond to requests to exercise your rights within one month of receipt. If necessary, this period may be extended by up to two months, depending on the complexity and number of requests. You will be informed of the reason for the delay.

Information related to the exercise of rights is provided free of charge, unless the request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee or decline the request.

Dorivo may request additional information to verify your identity if we have reasonable doubts.

13. Updates to this policy

We reserve the right to update this privacy policy. Changes will be published on the website, and we will notify you of material updates in a clear manner. Unless otherwise stated, changes take effect when the updated policy is published.