DAIBOLA

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Privacy Policy

Introduction

  1. We are committed to safeguarding the privacy of our website visitors and service users. We do not collect any personal information when you visit our site as a visitor. We do not use any web tracking technology.
  2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
  3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
  4. In this policy, “we”, “us” and “our” refer to DAIBOLA Trade Ltd. For more information about us, see Our Details.

How we use your personal data

  1. In this section we have set out:
    1. the general categories of personal data that we may process;
    2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
    3. the purposes for which we may process personal data; and
    4. the legal bases of the processing.
  2. We may process data about your use of our website and services (“usage data”). The usage data may include the date and time of your access, your IP address, geographical location, browser type and version, operating system, and referral source. The source of the usage data is the log files of our web-server. This usage data may be processed for improving the safety of our website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving the safety our website and services.
  3. We may process your Online Learning System (OLS) account data (“learning account data”). The learning account data may include your name and e-mail address. The source of the learning account data is you or your employer or your school. The learning account data may be processed for the purposes of operating our Online Learning System, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and/or the performance of a contract between your employer or school and us.
  4. We may process your information included in your personal “Protect + Care” profile (“Protect + Care data”). The Protect + Care data may include your name, address, telephone number, e-mail address, profile pictures, gender, date of birth, relationship status, languages you can speak, contacts of people to be informed in an emergency, and medical details. The Protect + Care data may be processed for the purposes of enabling and monitoring your use of our website and services. The Protect + Care data may be translated to other languages. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
  5. We may process your information which you entered at the service d’adresse mondial, for example, via the website http://sedamo.info/ or other websites (“sedamo data”). The sedamo data may include your name, gender, address, sedamo address code, shipping information, telephone number, mobile phone number, fax number, e-mail address, date of birth, and languages you use. The sedamo data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
  6. We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business .
  7. We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
  8. We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
  9. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your bank account details, your credit card details, your account name at the payment service provider and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
  10. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
  11. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
  12. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
  13. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
  14. In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  15. Please do not supply any other person's personal data to us, unless we prompt you to do so.

Providing your personal data to others

  1. We may disclose your personal data related to publication data (as described above) to printing companies insofar you have agreed to this.
  2. We may disclose your personal data related to publication data (as described above) to companies using our services insofar you have agreed to this.
  3. We may disclose your personal data related to publication data (as described above) to users of our website insofar you have agreed to this.
  4. We may disclose your personal data related to Protect + Care data (as described above) to printing companies to print your SOS Card and related printed material.
  5. We may disclose your personal data related to Protect + Care data (as described above) to medical doctors, dentists, hospitals, fire fighters, rescue services, any other kind of medical care providers, and so on, insofar as reasonably necessary to fulfil the purpose of the Protect + Care service.
  6. We may disclose your personal data related to sedamo data (as described above) to individuals and companies using our services insofar you have agreed to this.
  7. Financial transactions relating to our website and services may be handled by our payment services providers, Mollie B.V., Netherlands, and PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at http://www.mollie.com/en/privacy and http://www.paypal.com/uk/webapps/mpp/ua/privacy-full
  8. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
  9. In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

International transfers of your personal data

  1. In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
  2. We may disclose your personal data related to publication data (as described above) to printing companies insofar you have agreed to this.
  3. We may disclose your personal data related to publication data (as described above) to companies using our services insofar you have agreed to this.
  4. We may disclose your personal data related to publication data (as described above) to users of our website insofar you have agreed to this.
  5. We may disclose your personal data related to Protect + Care data (as described above) to printing companies to print your SOS Card and related printed material.
  6. We may disclose your personal data related to Protect + Care data (as described above) to medical doctors, dentists, hospitals, fire fighters, rescue services, any other kind of medical care providers, and so on, as well as to international organisations (such as, the International Red Cross) insofar as reasonably necessary to fulfil the purpose of the Protect + Care service. Transfers to these persons and organisations listed above will be protected by appropriate safeguards, namely the use of secured cryptographic protocols that provide communications security over computer networks, if these technologies can be used.
  7. We may disclose your personal data related to sedamo data (as described above) to users of our websites or services insofar you have agreed to this.
  8. You acknowledge that personal data that you submit for publication through our website or services may be available, via the Internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

Retaining and deleting personal data

  1. This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
  2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  3. We will retain your personal data as follows: ¤ We will determine the period of retention based on the following criteria:
    1. Personal data related to usage data (as described above) will be retained for a maximum period of five weeks after your last access on our servers.
    2. Personal data related to learning account data (as described above) will be retained while you attend a course and keep your account. After finishing all courses, you can delete your account, and all data will be removed within twenty-four hours from our servers. Copies of your data may remain on backups for no longer than five weeks.
    3. Personal data related to Protect + Care data (as described above) will be retained while you keep your account and/or use a SOS Card related to your account. After you handed back your SOS Card(s), you can delete your account, and all data will be removed within twenty-four hours from our servers. Copies of your data may remain on backups for no longer than five weeks.
    4. Personal data related to sedamo data (as described above) will be retained while you store your e-mail address in the service d’adresse mondial. You can delete your data, for example, by following the link provided in an automated e-mail and choosing “Robinson me”, and all data will be removed within twenty-four hours from our servers. Copies of your data may remain on backups for no longer than five weeks.
    5. Personal data related to publication data (as described above) will be retained while the company you represent will be listed in our print publications and/or listed in our digital publications and/or can be retrieved via our website or digital services. After the company has been removed from these lists, your personal data will be kept for a maximum period of twelve months. If you ask to remove the data, or you can delete your data yourself by accessing your profile by the link we sent to you. Your data will not be electronically accessible after removal. Your data will still be accessible in earlier publications (e.g., books). For historical records, we may keep a copy of these data on digital media for five years after the removal. We and the British National Library will keep copies of books.
    6. Personal data related to enquiry data (as described above) will be retained for a minimum period of five weeks following the date of your enquiry, and for a maximum period of five years following your enquiry.
    7. Personal data related to customer relationship data (as described above) will be retained for a minimum period of five weeks following the date of the establishment of the relationship, and for a maximum period of five years after this relationship has ended.
    8. Personal data related to transaction data (as described above) will be retained for a period of ten years after the transaction has been completed.
    9. Personal data related to notification data (as described above) will be retained for the time you wish to receive notifications (such as, e-mail newsletters) from us. After you decided not to receive notifications any longer, and all data will be removed within twenty-four hours from our servers. Copies of your data may remain on backups for no longer than five weeks.
    10. Personal data related to correspondence data (as described above) will be retained for a minimum period of five weeks following the date of our last correspondence, and for a maximum period of ten years after our last correspondence. ¤¤
    11. Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Amendments

  1. We may update this policy from time to time by publishing a new version on our website.
  2. You should check this page occasionally to ensure you are happy with any changes to this policy.
  3. This privacy statement was last updated on December 1, 2021. A notice will be posted on our web site home page for thirty days whenever this privacy statement is changed in a material way.

Your rights

  1. In this section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
  2. Your principal rights under data protection law are:
    1. the right to access;
    2. the right to rectification;
    3. the right to erasure;
    4. the right to restrict processing;
    5. the right to object to processing;
    6. the right to data portability;
    7. the right to complain to a supervisory authority; and
    8. the right to withdraw consent.
  3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
    • You can access — and delete — your personal data stored for publication by visiting http://key.daibola.biz/ and entering the key we sent to you, or by using the link we sent in our e-mail communication.
    • You can access your personal data stored for learning purposes by logging into the Online Learning System and choosing the menu “Profile”.
    • You can delete your personal data stored for the service d’adresse mondial by following the link provided in an automated e-mail and choosing “Robinson me”.
  4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
  5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
  6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
  7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
  8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
  9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
  10. To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
  11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
  12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
  13. You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this section.

About cookies

  1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
  2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
  3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

  1. We use a “session” cookie on this site. This cookie does not record any personal information. It is used to remember any preferences that you have set for the site whilst you are on our site. This cookie expires when you close your web browser. If you do not wish the session cookie to be set, you can disable cookies in your browser.
  2. Only if you wish to log-in for an online course (at the Online Learning System, OLS), you will have to accept a cookie which stores the credentials for your access. You can choose to log-in permanently to the OLS (menu item “Remember me” or similar) which will store a permanent cookie on your computer. You can safely delete this cookie at any time and then manually log-in (using your username and password) to the OLS the next time.

Cookies used by our service providers

  1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
  2. We use PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg, to process payments and to provide an online shopping cart. This service uses cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect the website and services generally. It also uses cookies to maintain an electronic shopping cart which stores items to be bought. You can view the privacy policy of this service provider at http://www.paypal.com/uk/webapps/mpp/ua/privacy-full .The relevant cookies are listed at http://www.paypal.com/uk/webapps/mpp/ua/cookie-full
  3. We use Care Concept AG to provide an online insurance contract form. This service uses cookies for taking steps, at your request, to enter into an insurance contract. You can view the privacy policy of this service provider at http://www.care-concept.de/wir_ueber_uns/datenschutz.php .The relevant cookies are sent from care-concept.de

Managing cookies

  1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
  2. Blocking all cookies will have a negative impact upon the usability of many websites.
  3. If you block cookies, you will not be able to use all the features on our website.

Our details

  1. This website is owned and operated by DAIBOLA Trade Ltd.
  2. We are registered in England and Wales under registration number 6662944, and our registered office is at 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom.
  3. You can contact us:
    1. by post, to the postal address given above;
    2. using our website contact form; or
    3. by email, using privacy@daibola.biz
Last modified: 2021-12-01 16:47

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