DTTD Company Limited 
Privacy Policy

Dotted Company Limited (“DTTD”) respects your privacy and is committed to protecting your Personal Information. We want to be transparent with you about how we collect and use your Personal Information in making available (i) the DTTD website at https://dttd.io (the Site), (ii) DTTD's related online and mobile services as described in the Terms of Use. Remember that your use of DTTD’s Services is at all times subject to our Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in our Terms of Service.

By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. We may gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.

 

If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children's Online Privacy if we learn that we have received any information directly from a child without first receiving his or her parent's verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our Services and subsequently we will delete that information.

 

Will DTTD ever change this Privacy Policy?

We're constantly trying to improve our Services and how we approach privacy matters, so we may need to change this Privacy Policy from time to time, but we will alert you to changes by requiring you to log in to our Services again and accept the new Privacy Policy and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used.

What Information does DTTD Collect?

Data You Provide to Us: We receive and store any information you knowingly provide to us. For example, this includes information you provide when you import your Wallet such as information regarding your transactional history on the Ethereum network, information you provide each time you wish to make a transfer of Virtual Currency through the Services, or usage information, such as information about how you use the Service and interact with us. It also includes:

Identity data

 

First name, surname, date of birth, facial recognition via forward-facing camera, identification documents for conducting the Know-Your-Client (KYC) procedures.

 

Contact data

Email address for DTTD to contact you. Telephone numbers and residential address for conducting KYC procedures.

 

Financial data

Payment card details.

Transaction data

Any details about payments to and from you and other details of services you have purchased from us. Data in respect of your transactions with third parties.

  

Service data

Your data that you provide to us when you report a problem or ask a question in respect of our Services or when you request further services from us. If you contact us, we may keep a record of that correspondence.

Technical data

This includes:

  • Device information: We may collect information about the device you use to access the Services, including your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, mobile network information, telephone number and other technology on the devices you use to access our Services.

  • Location information: When you use one of our location-enabled Apps or Services, we may collect and process data about your actual location.

  • Log information: We may automatically collect and store certain information about your use of the Services in server logs, including but not limited to internet protocol (IP) addresses, internet service provider, clickstream data, browser type and language, viewed and exited pages and date or time stamps.

  • Unique application numbers: When you install or uninstall an App containing a unique application number or when such an App searches for automatic updates, that number and information about your installation, for example the type of operating system, may be sent to us.

Special Category of Personal information

Application \ User Account Profile Picture.

Data Collected from Other Sources: In addition to the Personal Information that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Information from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

Data Collected from Other Sources: In addition to the Personal Information that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Information from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

  

Third-party data source

Social Media

Publicly Available?

  • Yes

Category(ies) or other types of Personal information received

  • Identity data

  • Contact data

Pour Affiliates

Publicly Available?

  • No

Category(ies) or other types of Personal information received

  • Identity data

  • Contact data

Data Collected Automatically (Cookies Policy): Whenever you interact with certain parts of our Services such as our landing page located at https://dttd.io or any of our webpages (collectively, the “Site”), we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. We typically collect this information through a variety of tracking technologies, including cookies, embedded scripts, web beacons, file information and similar technology (collectively, “tracking technologies”). “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Site are visited and by how many people.

Our Site uses the following types of cookies for the purposes set out below:

Strictly Necessary Cookie

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and require you to re-enter your password after a certain period of time has elapsed to protect you against others accidentally accessing your account contents. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies are used to recognize you when you return to our Site and allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site. We also use these cookies to obtain information about your visit, including items you viewed or searched for, page response times and download errors.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, for example, by ensuring that users are finding what they are looking for easily, as well as to gather broad demographic information and to monitor the level of activity on our Site. We also use these cookies to obtain information about your visit, including the full Uniform Resource Locators (URL) clickstream data, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from webpages.

 

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies.

You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the settings, help tools or edit facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.

 

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org

 

In particular, you can disable cookies which remember your browsing habits and target advertising at you by visitinghttp://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.

 

You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en-GB

 

To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout and download and install the linked add-on for your current web browser. The Google Analytics Opt-out Browser Add-on is available for Microsoft Internet Explorer, Google Chrome, Mozilla Firefox, Apple Safari and Opera.

 

Please note that certain third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. If you would like to disable these "third party" cookies generated by advertisers or providers of targeted advertising services, you can turn them off by going to that third party's website and setting your cookie preferences to stop any further cookies being written to your device.

 

Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services.

 

We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services - for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible. We do not automatically collect Personal Information or other nonpublic information in connection with transactions you conduct using our Services through the DTTD Interface, DTTD MVP and we do not use any automatic tracking technologies in these parts of our Services unless you explicitly agree to the use of these tracking technologies.

 

Do Not Track Policy: Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked.

 

We do not track our users over time and across third party websites to provide targeted advertising and therefore we do not respond to Do Not Track requests. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you, and these third parties may not honor Do Not Track requests. Remember that this is just our Do Not Track policy, and we can’t and don’t make any promises about how third parties react when you set this signal on your browser, including any third- party sites we may link to. You should always review the Privacy Policy and specifically, the Do Not Track policy, of a third-party site to understand how they will respond to Do Not Track requests.

 

Information we will never collect: We will never ask you to share your private keys to your Wallet or other security information that could be used to access your Wallet without your explicit consent and action. Never trust anyone or any site that asks you to enter your private keys or similar security information.

   

How does DTTD Use the Personal Information it Receives?

As a general policy, we aim to protect your privacy and Personal Information by collecting, using or sharing as little Personal Information as possible in order to provide our Services.

 

In respect of the purposes for which we use your Personal Information, we will rely on one of the following legal bases:

  • Where we need to perform a contract we are about to enter into or have entered into with you (Contractual Necessity).

  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (Legitimate Interests). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Information for is set out in the table below.

  • Where we need to comply with a legal or regulatory obligation (Compliance with Law).

  • Where we have your specific consent to carry out the processing for the Purpose in question (Consent).

     

We will process your personal information if you give us your consent willingly or in accordance with the law. You give your consent to us through the use of our product and services. We will only disclose your personal information if:

  • the law requires it;

  • we have a public duty to disclose the information;

  • our or your legitimate interests require disclosure; or

  • you agreed that we may disclose your information.

     

Generally, we do not rely on your Consent as a legal basis for using your Personal Information, other than in the context of direct marketing communications.

To the extent we do use Personal Information, we use such information to provide and improve the Services, optimize our technology, refine the experience of DTTD users, and innovate ways to forward our mission. Without your personal information, we may not be able to provide or continue to provide you with the products or services that you need.

Namely, we use the information we collect to:

Account creation

 

Category(ies) if personal information involved

  • Identity data

  • Contact data

  • Technical data

 

Why do we do this

  • To register you as a new customer and to conduct Know-Your-Client.

Our legal basis for this use of data

  • Contractual Necessity.

  • Compliance with Law.

   

To process payments (and their associated services and functionalities)

 

Category(ies) if personal information involved

  • Identity data

  • Contact data

  • Financial data

  • Transaction data

 

Why do we do this

  • To process and deliver your order including manage payments, fees and charges.

Our legal basis for this use of data

  • Contractual Necessity. 

Fraud prevention

Category(ies) if personal information involved

  • Identity data

  • Contact data

  • Financial data

  • Transaction data

 

Why do we do this

  • To keep our services and associated systems operational and secure.

Our legal basis for this use of data

  • Legitimate Interests.

  • We have a legitimate interest in ensuring the ongoing security and proper operation of our services and ensuring we are within our processing obligation with our payment service providers.

  • We have a legitimate interest in ensuring the ongoing security and proper operation of our services and ensuring we are within our processing obligation with our payment service providers.

Troubleshooting

Category(ies) if personal information involved

  • Identity data

  • Contact data

  • Service data

  • Transaction data

  • Technical data

 

Why do we do this

  • To track issues that might be occurring on our systems and to notify you of updates and security alerts

Our legal basis for this use of data

  • Legitimate Interests.

  • It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Services and associated systems and services.

 

Data analysis, and improvements to our service

Category(ies) if personal information involved

  • Identity data

  • Contact data

  • Service data

  • Behavioral data

  • Technical data

Why do we do this

  • To carry out audits and data analysis to identify usage trends, improve the Services and improve the effectiveness of our communications.

Our legal basis for this use of data

  • Legitimate Interests.

  • It is in our legitimate interests that we are able to use audit and data analysis to improve the Services and improve the effectiveness of our communications.

Customer services

Category(ies) if personal information involved

  • Identity data

  • Contact data

  • Service data

  • Technical data

Why do we do this

  • To provide customer service, including to respond to your enquiries and fulfil any of your requests for information in respect of the Services.

Our legal basis for this use of data

  • Contractual Necessity.

Personalization

Category(ies) if personal information involved

  • Identity data

  • Service data

  • Behavioral data

  • Technical data

Why do we do this

  • To personalize your experience on the DTTD App by presenting information tailored to you and your geographic location.

Our legal basis for this use of data

  • Legitimate Interests.

  • It is in our legitimate interests that we are able to provide a more personalized service to you to improve your experience of the Services.

Marketing

 

Category(ies) if personal information involved

  • Identity data

  • Contact data

  • Marketing and Communication data

Why do we do this

  • To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

Our legal basis for this use of data

  • Legitimate Interests.

  • We have a legitimate interest in providing you with updates on our Services, including in-App promotions, upcoming events, and other news about products and services offered by us and related offers where you have purchased or shown interest in similar services from us.

Compliance with law and regulation

Category(ies) if personal information involved

  • All relevant data

Why do we do this

  • We may use data as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process Depending on the circumstances, our legal basis may be: and our regulators; (c) to respond to requests from public and government authorities; (d) to enforce or apply this Privacy Policy or our Terms of Service; (e) to protect our operations; (f) to protect our rights, privacy, property or safety, and/or that of you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Our legal basis for this use of data​

Depending on the circumstances, our legal basis may be:

  • Compliance with a legal obligation to which we are subject;

  • Necessity to protect your vital interests or those of another person;

  • Legitimate Interests.

Will DTTD Share Any of the Personal Information it Receives?

We do not share or sell the Personal Information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We may share your Personal Information with third parties as described below:​

  • Consent: We may share Personal Information with your explicit consent.

  • Affiliated Businesses: In certain situations, businesses or third-party websites we’re affiliated with may sell

    or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all of these business’ or websites’ policies.

  • Our Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you or to us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

  • Business Transfers: We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

  • Third Party Services: We may use third party services, such as Google Analytics, to grow our business, to improve and develop our Services, to monitor and analyze use of our Services, to aid our technical administration, to increase the functionality and user-friendliness of our Services, and to verify that users have the authorization needed for us to process their requests. These services may collect and retain some information about you, such as the IP address assigned to you on the date you use the Services, but not your name or other personally identifying information. We may combine the information generated through the use of these services with your Personal Information but never in a way that will identify you to any other user or third party. Although these services may plant a persistent cookie on your web browser to identify you as a unique user the next time you use the Services, the cookie cannot be used by anyone but Google. These services’ ability to use and share information about your use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You may find additional information about Google Analytics at https://google.com/policies/privacy/partners/. You can opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/. We also use a tool called Amplitude to collect information about your use of the Services. We use the information we get from Amplitude only to improve our Services. Amplitude’s ability to use and share information collected by Amplitude in connection with our Services is governed by Amplitude’s Terms of Service at https://amplitude.com/terms and Privacy Policy at https://amplitude.com/privacy. Our Services also use Intercom to provide support and to conduct user outreach. Intercom also provides us with certain analytics to improve our Services. Intercom’s ability to use and share information collected by Intercom in connection with our Services is governed by Intercom’s Terms of Service, Privacy Policy, and other terms and conditions located at https://www.intercom.com/terms-and-policies.

  • Protection of DTTD and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of DTTD, our employees, our users, or others.

When we share Personal Information, we will not share such Personal Information in a manner that can be used to identify you individually or in a manner that provides more Personal Information than is publicly available (if applicable) unless otherwise explicitly agreed by you or instructed by you.

Is Personal Information about me secure?

We endeavor to protect the privacy of the Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. The safety and security of your Personal Information also depends on you. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Your Wallet is protected by your password, private key, and/or seed phrase, and we urge you to take steps to keep this and other Personal Information safe by not disclosing your security credentials or leaving your Wallet open in an unsecured manner. We further protect your Personal Information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. We also seek to protect Personal Information by refraining from collecting Personal Information where possible. However, these measures do not guarantee that your Personal Information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Services, you acknowledge that you understand and agree to assume these risks.

WE DO NOT AND WILL NEVER STORE YOUR WALLET PASSWORD, PRIVATE KEY, OR SEED PHRASE TO YOUR WALLET. IF YOU LOSE ACCESS TO BOTH YOUR PASSWORD AND SEED PHRASE, WE WILL BE UNABLE TO HELP YOU ACCESS YOUR WALLET, AND ANY ASSETS HELD IN THE WALLET MAY BE PERMENANTLY IRRETRIEVABLE.

 

We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

 

EU RESIDENTS

 

If you are a resident of the European Economic Area (“EEA”) or Switzerland, you may have additional rights under the General Data Protection Regulation (the “GDPR”) and other applicable law with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. DTTD will be the controller of your Personal Data processed in connection with the Services.

 

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at help@dttd.io.

What Personal Data Do We Collect from You?

   

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

  • Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation, Personal Information as described above under “Information You Provide to Us” and “Information Collected from Other Sources”, and any other information you may elect to submit in your communications with us while using our Services. You are not required to submit Personal Data solely in connection with your use of your Wallet through our Services, but certain of our other Services may require submission of Personal Data to fully exploit those Services.

  • Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, including without limitation, the information described above under “Information Collected Automatically.”

 

​​

How Do We Use Your Personal Data?

 

 

We process Personal Data to operate, improve, understand and personalize our Services. See “How does DTTD Use the Personal Information it Receives?” for more information on how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

​​

  • Contractual Necessity: We process certain Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

  • Legitimate Interest: We may also process your Personal Data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We consider and balance any potential impacts on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law). Examples of these legitimate interests include operation and improvement of our business, products and Services, provision of customer support, protection from fraud or security threats, compliance with legal obligations or completion of corporate transactions.

  • Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

  • Other Processing Grounds: From time-to-time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data?

 

We share Personal Data with our agents, third party service providers who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service, potential business partners in connection with business transfers described in this Privacy Policy, or for legal purposes. Please see “Will DTTD Share Any of the Personal Information it Receives?” for more information.

How Long Do We Retain Your Personal Data?

We retain Personal Data about you for as long as necessary to provide you Services. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we may retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use?

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity, and, where possible, we refrain from collecting Personal Data. For example, DTTD does not collect private key data associated with your Wallet, and we secure the Personal Data you provide in a controlled, secure environment and protected from unauthorized access. DTTD regularly audits its system for any possible security vulnerabilities to safeguard Personal Data. DTTD protects the security of your information during transmission by using Transport Layer Security (TSL/SSL), which encrypts all information that you input. However, your private key is the key to your Wallet. If you do share your private key or your Personal Data with others that enables them to access your private key, you remain responsible for all actions taken in the name of your Wallet. If you lose control of your private key, you may lose control over your Wallet or your Personal Data and may be subject to legally binding actions taken of your behalf.

 

What Rights Do You Have Regarding Your Personal Data?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email help@dttd.io. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary, to verify your identity and the nature of your request.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by visiting the DTTD Interface or the DTTD App.

  • Rectification: If you believe that any Personal Data, we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can correct some of this information directly by editing them on the DTTD Interface or the DTTD App.

  • Erasure: You can request that we erase some or all your Personal Data from our systems, provided that this will not erase any Personal Data you have submitted to the Ethereum network.

  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.

  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

  • Right to File Complaint: You have the right to lodge a complaint about DTTD’s practices with respect to

    your Personal Data with the supervisory authority of your country or European Union Member State.

     

Transfers of Personal Data

 

Certain of the Services are hosted and operated in Hong Kong through DTTD and its service providers, and if you do not reside in Hong Kong SAR, laws in Hong Kong may differ from the laws where you reside. By using the Services

and providing your information, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, may be provided to DTTD in Hong Kong and may be hosted on Hong Kong servers. You hereby consent to and authorize DTTD to transfer, store and process your information to and in the Hong Kong, and possibly other countries or regions. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Policy. One such step we may take to ensure the security of your Personal Information in the event that a transfer may not be subject to the same protection in the EEA or Switzerland, is to enter into specific contract clauses approved by the European Commission which ensure your personal information is given the same protection it has in Europe.

 

What If You Have Questions Regarding Your Personal Data?

If you have any questions about this section or our data practices generally, please send us a detailed message to help@dttd.io, and we will try to resolve your concerns.

 

HONGKONG RESIDENTS

If you are a Hong Kong resident, Hong Kong Data Privacy Law may provide you with additional rights regarding our use of your Personal Information. To learn more about your Hong Kong privacy rights, visit https://www.pcpd.org.hk/english/data_privacy_law/ordinance_at_a_Glance/ordinance.html

 

What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to help@dttd.io, and we will try to resolve your concerns.