Privacy Policy

This is the Privacy Notice for Exchanga

This website is the property of UAB “Doglinma” (the “Company”). We take the privacy of all visitors to this website very seriously and therefore set out in this privacy notice our position regarding certain privacy matters and the use of cookies for these websites.

This notice covers all data that is shared by a visitor with us whether directly via www.exchanga.com or via email. This notice provides an explanation as to what happens to any personal data that you share with us, or that we collect from you either directly via this website or via email.

The Company is committed to safeguarding your privacy and handling your personal data in an open and transparent manner which respects the privacy of any user that accesses our site(s). Our Privacy Notice Online Statement policy is intended to explain how we protect the privacy of your personal information. We will only use your information as described in our Privacy Notice Online Statement policy.

This document will help you understand the following:

  1. What personal data we collect and process about you as a customer and as a user of our website, mobile applications and online services;
  2. Why we collect and process your data;
  3. How the Company collects and processes your personal data;
  4. Where we obtain the data from;
  5. Your rights under the local data protection law and the EU General Data Protection Regulation (‘GDPR’);
  6. How and when we share your personal data with other third parties (for example, our service providers or suppliers).

Information we collect

  1. Email address
  2. First name and last name
  3. Phone number
  4. Address, State, Province, ZIP/Postal code, City
  5. Job title, profession
  6. Pictures you submit

Those information may processed for the purposes to provide you with our services, protecting you from any illegal activity, maintaining legal and regulatory compliance, communicating with you, prevent and/or detect and investigate fraud, money laundering and/or other criminal or misuse of our service.

Information Collected Automatically

Like many websites, we and our third-party service providers, such as advertising and analytics providers, use cookies, web beacons and other data technologies to receive and store certain types of information when you interact with us through your computer or mobile device. Using these technologies helps us recognize you, customize your experience and make relevant marketing messages. Here are some of the types of information we collect:

  1. Log & Device data. When you visit our site, we may automatically record information
    (“log data”), including information that your browser sends whenever you visit our site. This log data may include your web address you came from or are going to, your device model, operating system, browser type, unique device identifier, IP address, mobile network carrier, and time zone or location.
  2. Our third-party service providers may provide us information that tells us how marketing ads are, often placed on third party sites, performed and who clicked on them. This information does not identify any specific individual and is generally non-identifying. If we were to associate it with you, we would treat it as personal data.

Use of your information - Grounds for Using Your Personal Data

The information that we collect and store relating to you is primarily used to enable us to provide our services to you. In addition, UAB “Doglinma” is relying on the following lawful grounds to collect and process any personal data you may have provided:

  1. Legitimate Business Interests: To provide you with information requested from us relating to our products or services and to provide information on other products which we feel may be of interest to you if you have consented to receive such information, which are legitimate business interests. To notify you about any changes to our Website, such as improvements or service/product changes, that may affect our service. If you are an existing customer, we may contact you with information about goods and services similar to those which were the subject of a previous sale to you.
  2. Performance of Contract: To meet our contractual commitments to you and in performance of contractual obligations to you.
  3. User Consent: We may use your data, or permit selected third parties to use your data, so that you can be provided with information about unrelated goods and services which we consider may be of interest to you. We or they may contact you about these goods and services by any of the methods that you consented to at the time your information was collected. If you are a new customer, we will only contact you or allow third parties to contact you only when you have provided consent and only by those means you provided consent for. If you do not want us to use your data for ourselves or third-parties, you will have the opportunity to withhold your consent to this when you provide your details to us on the form on which we collect your data.
  4. Please be advised that we do not reveal information about identifiable individuals to our advertisers, but we may, on occasion, provide them with aggregate statistical information about our visitors such as your area of residence or age group.

Please be advised that we do not reveal information about identifiable individuals to our advertisers, but we may, on occasion, provide them with aggregate statistical information about our visitors such as your area of residence or age group.

Your obligation to provide us with your data

The establishment and legality of the contractual relationship between yourself and the Company is dependent on the provision by yourself of the data requested by the Company. You must provide to us those of your personal data are necessary for commencement and execution of a contractual-based business relationship between ourselves and for the performance of both parties’ contractual obligations.

To maintain the contractual relationship and to receive services from the Company, you are obliged to provide us with certain personal data, as we are compelled by applicable AML/CTF legislation and regulations to identify you, verify your identity and perform due diligence or enhanced due diligence if applicable on your person to fulfil our AML obligations.

If you fail to provide us with the requested data, the commencement or the continuation of our business relationship will not be possible

Sharing and Disclosure

We do not share your personal information with others except as indicated within this notice or when we inform you and give you an opportunity to opt out of having your personal information shared.

We will share your information in the following ways.

  1. With third party service providers, agents, or contractors. We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to process credit card transactions or other payment methods. Or, we may engage Service Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide customer service, to collect debts, and to analyze and enhance data (including data about users’ interactions with our service). These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third party providers on our behalf. We do not authorize them to use or disclose your personal information except in connection with providing their services.
  2. Analytics. Specifically, for analytics providers, we use Google Analytics which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

    You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/ Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout –

    for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

  3. Advertising. We may use third-party Service Providers to show advertisements, which may include targeted advertisements on a third-party site after you have visited our website. We and the third-party service providers use cookies to inform, optimize, measure performance serve ads based on your previous visits to our site. Any tracking that a third party performs is subject to their own privacy notice.

Please note at this time, we do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.

We work with Google AdSense & DoubleClick Cookie Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Google AdWords/Analytics

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page at http://www.google.com/intl/en/policies/privacy/

Twitter: You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405 You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy Facebook: You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook’s interest-based ads follow these instructions from Facebook:

https://www.facebook.com/help/568137493302217

To see more about Facebook’s participation in the Digital Advertising Alliance please visit the Choices section of this notice.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy:

https://www.facebook.com/privacy/explanation

We may participate in Facebook.com’s Custom Audience or LinkedIn’s Audience program which enables us to display personalized ads to persons on our email list when they visit Facebook or LinkedIn respectively. We provide Personal Information such as your email address and phone number to the social media provider to enable it to determine if you are a registered account holder. You may opt-out of participation in this program by contacting us as noted below. You may also opt out of receiving these ads from the social media network directly.

  1. Payment Providers: We may provide paid products and/or services within the site. When we do, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their own privacy notice. The payment processors we work with adhere to

    the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard and others. PCI-DSS requirements help ensure the secure handling of payment information.

    In case, if you require more details about our payment processors, you are welcome to send your request-inquiry to support@exchanga.com

  2. To comply with legal process or to protect Company. If we believe that disclosure is reasonably necessary to comply with a law, regulation, legal or governmental request; to enforce applicable terms of use, including investigation of potential violations thereof; to protect the safety, rights, or property of the public, any person, or Company as required by law; or to detect, prevent, or otherwise address, security or technical issues or illegal or suspected illegal activities (including fraud).
  3. Business Transfers. We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this notice. In such transitions, customer information is typically one of the business assets that is transferred or acquired by a third party. In the unlikely event that we or substantially all our assets are acquired or enter a court proceeding, you acknowledge that such transfers may occur and that your personal information can continue to be used as set forth in this privacy notice.

Storing your personal data/Transfer of Data

This site is operated in the EU. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in EU. By using this site and providing us with information, you consent to this transfer, processing and storage of your information in the EU. It is important to note that the privacy laws in the EU may not be as comprehensive as those in other countries such as the United States. Our service providers use appropriate safeguards to transfer your personal data.

We may transfer data that we collect from you to locations outside of headquarters for processing and storing. In addition, it may be processed by staff operating outside the office area who work for us or for one of our suppliers. For example, such staff may be engaged in the processing and concluding of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all reasonable steps to make sure that your data is treated securely and in agreement with this privacy notice.

  1. Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into via our site will be encrypted to ensure its safety.
  2. The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and the transmission of such data is entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential.

Third party links

We may have links on our site to other sites that we do not operate. If you click on a third-party link, you will be taken directly to that site which is governed by its own privacy notice. We strongly encourage you to read that privacy notice. We do not control that site and assume no responsibility for the content, policies or its practices.

Choices and Individual Rights:

We aim to take reasonable steps, so you can correct, amend, delete or limit the use of your Personal Data.

We outline your choices below:

  1. E-mail. As described above, if you do not wish to receive promotional e-mails from us, you may opt out at any time. If you opt out of a promotional e-mail, we may still send you transactional and administrative emails about this privacy notice or about the products or services you have purchased.
  2. Cookies. Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time.
  3. Advertising. You can opt out of online targeted advertising by opting out within the advertisement itself or by visiting Digital Advertising Alliance, http://www.aboutads.info/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/. You can also opt out of the Digital Advertising Alliance using your mobile device settings.
  4. Withdraw consent. Where you have consented to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once your consent is withdrawn, the processing of your data will be halted, unless said processing is found on another legitimate basis, for example due to a legal obligation to keep your data.

Your rights under certain circumstances.

  1. Right to information.

    You may request to know whether we hold any of your personal data, and, if so, information on the Company, what type of data we process and why/how we are processing it.

  2. Right of access.

    This right is giving you the opportunity to request and receive a copy of your personal data and check that the processing is lawful.

  3. Right to rectification.

    You have the right to request rectification of the information that we hold. You have also the right to ask us to complete any incomplete data we may hold.

  4. Right to erasure (‘right to be forgotten’).

    You may request that your personal data is deleted, provided that you meet the legal criteria for this request. Generally, you may request to be forgotten if the processing is unnecessary, unlawful, illegitimate, or you have objected to it. Note that since the majority of the processing performed by the Company is based on legal requirement, your request to be forgotten may be legally rejected by the Company.

  5. Object to processing of your personal information.

    If we are processing your data based on our (or a third party’s) legitimate interest and you are in a particular situation which gives you reason to object to the processing, you may submit this request. You may also object if we are processing your data for direct marketing purposes. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.

  6. Object to automated decision-making including profiling.

    You may object to any automated decisions or profiling taken and performed by us based on your personal data.

  7. Right to restriction.

    You may request the restriction of the processing of your data under some circumstances, for example, to determine if the data is accurate or to establish the reason for processing it.

  8. Right to data portability.

    This right only applies to information that you have given to us. You have the right to ask that we transfer the information you gave us from one organization to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

Please contact the Company’s Data Protection Officer at support@exchanga.com if you wish to exercise your rights. We may apply identification verification measures to you in order to ensure that no personal data is disclosed to unauthorized persons.

Unless your requests are manifestly unreasonable or excessively burdensome, you shall not be charged a fee by the Company. In such cases your requests may also be denied, as they may not be submitted in good faith.

Security

We use reasonable administrative, logical, physical, technical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee a 100% security of your information.

Retention

The retention period for your data is primarily dependent on the retention rules imposed upon us by the applicable legislation. We are obliged by various laws to keep your data for a specific amount of time. Destruction of the data prior to the lapse of this period is not possible.

We shall keep your data for up to 10 (ten) years from the date of the creation of your account (with a margin of error of 1 (one) year) unless legal or regulatory reasons prohibit us from destroying the data.

When applicable, your data shall be securely deleted and/or destroyed and shall not be recoverable. We shall not notify you upon deletion as we will have no contact details to reach you.

If we anonymize your personal data so that it can no longer be associated with you or identify you it shall not be considered personal data as per the definition of the Law and we may keep that information without further notice to you.

UAB “Doglinma” will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

UAB “Doglinma” will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Sensitive Data

We request that you do not send us any sensitive data such as social security or national identification numbers, information related to racial or ethnic origin, political opinions, religious beliefs, health data, biometrics or genetic, criminal background or trade union membership information. If you do send us this information, then you are consenting to its processing in accordance with this privacy notice. To avoid processing of sensitive data, do not submit it.

Our policy on children’s information

Our site is not directed to children under 18. If you learn that your minor child has provided us with personal information without your consent, please contact us.

Complaints

If you have any complaints about the processing of your data, you may contact the Company’s Data Protection Officer at support@exchanga.com.

If you have exercised any of your rights and are not satisfied with the way the Company handled your request, please file a complaint at support@exchanga.com. Changes to this policy

We keep our privacy notice under regular review to make sure it is up to date and accurate.

Information about us

UAB “Doglinma”.

Eišiškių Sodų 18-oji g. 11, LT-02194 Vilnius. Last updated on March 19th, 2021

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