This Privacy Policy (“Privacy Policy”) is entered into by Dotgo LLC. (“Dotgo USA”), unless you are located in a country where Dotgo USA has an Affiliate and Your order is placed upon and processed by Dotgo USA’s Affiliate in Your country, in which case, Dotgo USA’s Affiliate in that country is the contracting entity (“Company” or “we” or “Dotgo” or “Us” or “Our”), and the entity accepting this Privacy Policy (“You” or “Client” or “Your”).
This Privacy Policy governs the manner in which the Company collects, uses, maintains and discloses information collected from You. This Privacy Policy applies to the Website and its associated Content and Services, and to all products and services offered by the Company, unless a more specific privacy policy has been explicitly notified by the Company in relation to that product or service.
BY USING THE WEBSITE OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE AND SHARING, DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE THE WEBSITE OR GIVE US ANY OF YOUR INFORMATION. IF YOU USE THE WEBSITE ON BEHALF OF SOMEONE ELSE (SUCH AS A MANAGER, SUPERVISOR, CO-WORKER) OR AN ENTITY (SUCH AS YOUR EMPLOYER OR YOUR CUSTOMER), YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.
Please note:
2. HOW WE USE COLLECTED INFORMATION
The Company may collect and use Your Information for the following purposes:
3. CHOICE
In accordance with the Data Privacy Framework, Dotgo limits the use and disclosure of Personal Data of Data Subjects (residing in the EU, US and Switzerland), and provides an opt-in choice for Sensitive Personal Data collected. If Personal Data is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized or is to be disclosed to sub-processors, Dotgo will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed. Dotgo, its aggregators or related party collecting personal data will obtain affirmative consent (i.e., opt-in) from Data Subjects. To opt out of such uses or disclosures of Personal Data or Sensitive Personal Data, Data Subjects or the aggregators may contact Dotgo by either submitting a data deletion request by e-mailing on dpo@dotgo.com.
4. HOW WE PROTECT YOUR INFORMATION
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Your Information, username, password, transaction information and data stored on our Website.
Sensitive and private data exchange between the Website and Client happens over an SSL (Secure Sockets Layer) secured communication channel and is encrypted and protected with digital signatures.
We cannot, however, ensure or warrant the security of any information you transmit, or guarantee that Your information on the Website may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Your privacy settings may also be affected by changes to the functionality of the Company’s distributors and suppliers, such as sub-processors and vendors involved in providing Services. We are not responsible for the lapses in functionality or security measures of any third party.
You are responsible for maintaining the secrecy of Your unique password and other related credentials, and for controlling access to Your e-mail communications from the Company, at all times, including but not limited to any suspicious activity under your account.
If you think that your credentials are or were being compromised at any given point of time, you may notify us immediately.
5. SHARING YOUR PERSONAL INFORMATION
In case You provide us with Personal Information, we shall assume that consent has been given to Us by You for obtaining the same.
We may use third party service providers to help us operate our business and the Website or administer activities on our behalf, such as providing Services, or sending out newsletters or surveys. We may share Your Personal Information with these third parties if needed to carry out the obligations and provide you with the services in an efficient manner.
Except as otherwise described in this Privacy Policy, we will not disclose Personal Information to any third party unless required to do so by law or if we believe that such action is necessary to conform to the law, comply with legal process served on us or our affiliates, or investigate, prevent, or act regarding suspected or actual illegal activities; to enforce our Terms of Use, take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our Website; and to exercise or protect the rights, property, or personal safety of the Company, our users or others.
Dotgo remains responsible and liable under the EU-U.S. DPF Principles, the UK extension to the EU-U.S. DPF and or the Swiss-U.S. DPF Principles if third party agents that it engages to process the Personal Data on its behalf do so in a manner inconsistent with the DPF Principles unless Dotgo proves that it is not responsible for the event giving rise to the damage.
6. THIRD PARTY WEBSITES
You may find advertising or other content on our Website that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Website. In addition, these sites or services, including their content and links, may be constantly changing. Please remember that when you use a link to go from the Website to another website, our Privacy Policy is no longer in effect. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Website, is subject to that website’s own terms and policies.
We are not responsible for the practices employed by websites linked to or from the Website, nor the information or content contained therein. Your browsing and interaction on any other website, including those that have a link on our “Website”, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding.
7. ADVERTISING
Ads appearing on our Website may be delivered to You by advertising partners, who may set cookies. These cookies allow the ad server to recognize Your computer each time they send you an online advertisement to compile non-personal identification information about you or others who use Your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to You. This Privacy Policy does not cover the use of cookies by any advertisers. All revenue generated through advertising on the Website belongs to the Company.
8. GOOGLE ADSENSE
Some of the ads on our Website and Bot Store may be served by Google. Google’s use of the DART cookie enables it to serve ads to You based on their visit to our Website and other sites on the Internet. DART uses “non-personally identifiable information” and does NOT track Information about You, such as Your name, e-mail address, physical address, etc. You may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy at http://www.google.com/privacy_ads.html.
9. YOUR RIGHTS
Unless subject to an exemption, You have the following rights with respect to Your data:
10. JURISDICTION AND ARBITRATION
This Privacy Policy shall be governed by the Jurisdiction and Arbitration clause of the Applicable Agreement.
Dotgo is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
11. CHANGES TO THIS PRIVACY POLICY
We may revise this Privacy Policy from time to time. If we do, the revised Privacy Policy will supersede any prior versions. We will provide you advance notice of any material revisions of the Privacy Policy at least fifteen (15) days prior to the revisions becoming effective, unless the regulatory bodies, legal requirements, telecom carriers, or IP Messaging Platforms necessitate a faster change. We also encourage You to frequently check this page for any changes to the Privacy Policy.
What constitutes a “material revision” will be determined at Our sole discretion, in good faith and using common sense and reasonable judgement. Your continued access or use of our Services constitutes Your acceptance of any revisions. If you don’t agree to the revisions, you should stop using Services, and in such a case, Company is not obligated to provide you with the Services.
12. YOUR ACCEPTANCE OF THESE TERMS
By using this Website or Services, you signify Your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Website and Services. Your continued use of the Website or Services following the posting of changes to the Privacy Policy will be deemed Your acceptance of those changes.
13. SEVERABILITY
Each paragraph of this Privacy Policy shall be and remain separate from and independent of and severable from all and any other paragraphs herein except where otherwise expressly indicated or indicated by the context of the agreement. The decision or declaration that one or more of the paragraphs are null and void shall have no effect on the remaining paragraphs of this Privacy Policy.
14. SPECIAL NOTICE TO INTERNATIONAL VISITORS AND CLIENTS
Because we operate globally, we may transfer Your Information within our global operations to fulfil our obligations to You, but always subject to the applicable data protection law and this Privacy Policy. Privacy laws differ across the globe. To help visitors whose native language may not be English understand our privacy practices, we may provide special information on our Privacy Policies that may be applicable to these visitors in different languages. The Company’s entities outside USA may have supplemental privacy policies that may apply in those countries. If You are visiting from the European Union or other regions with laws governing data collection and use that may differ from New Jersey law, including those whose privacy laws may be more strict than New Jersey law, please note that You are transferring Your Information to outside the European Union, to us. By providing Your Information you consent to that transfer and processing.
15. OUR POLICY TOWARDS CHILDREN
Dotgo Services are not directed to individuals under 18. We do not knowingly collect Personal Information from children under 18. If we become aware that a child under 18 has provided us with Personal Information, we will take steps to delete such information. If you become aware that a child has provided us with Personal Information, please contact our Support Services at rbm-support@dotgo.com.
16. RETENTION OF PERSONAL INFORMATION
We retain your personal information for the purpose defined in Section 2, and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
17. DATA PRIVACY FRAMEWORK
Dotgo complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Dotgo has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal Data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Dotgo has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, (collectively, the “DPF Principles”), the DPF Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit www.dataprivacyframework.gov
In Compliance with EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S DPF, Dotgo commits to resolve DPF Principles related complaints about our collection and use of your personal information. EU, UK or Swiss individuals with inquires or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. DPF should first contact dpo@dotgo.com . In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Dotgo commits to cooperate and comply respectively with the advice of the panel established by the EU Data Protection Authorities (DPAs), the UK Information Commissioner’s Office (ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of Personal Data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. If your complaint regarding our processing of Personal Data cannot be resolved through the above channels, you may invoke binding arbitration under the Data Privacy Framework. This option is available for residual claims that are not resolved by other dispute resolution or enforcement mechanisms. Binding arbitration is subject to certain preconditions, including:
18. DATA PROCESSING
18.1 DATA PROCESSING FROM EUROPEAN ECONOMIC AREA (“EEA”) CLIENTS
When personal data from inside the European Union is processed by Dotgo on Client’s behalf, it shall be governed by European data protection law including the Regulation (EU) 2016/679 (“GDPR”).
European data protection law including the Regulation (EU) 2016/679 (“GDPR”) requires organisations like the Company to provide a lawful basis to collect and use the Client’s information. The Company’s lawful basis to collect and use information from the Company’s EEA Clients include when:
As data processor, the Company will own and control Client’s information in accordance with GDPR in relation to the Clients on whom GDPR is applicable. The sub-processors used by the Company are listed at www.dotgo.com/data-processors-dotgo.
18.2 DATA PROCESSING FROM OUTSIDE EUROPEAN UNION
When personal data from outside the European Union is processed by Dotgo on Client’s behalf, it shall be processed as follows:
19. QUERIES AND GRIEVANCE OFFICER
Should you have questions about this Privacy Policy or the Company’s information collection, use and disclosure practices, you may contact, the Data Officer appointed by the Company. The Officer will respond to the queries within 30 (thirty) days of receiving the queries. If You have any grievance with respect to Our use of Your Information, You may communicate such grievance to the Data Officer:
Name: Data Officer
Address: 991 US-22, Suite 200, Bridgewater NJ 08807
E-mail ID: dpo@dotgo.com