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Privacy Policy 

Effective date: September 13, 2023

Last modified: September 13, 2023

DOMOVA LLC, its parents, subsidiaries, and affiliated entities respects your privacy, and we are committed to protecting it through our compliance with this Privacy Policy and all applicable laws and regulations. This Privacy Policy (which is published at domova.com/en/privacy-policy, hereinafter Privacy Policy) is intended to inform You about Our policies and procedures on the collection, use, processing, and disclosure of Your Personal Data when You use the Platform and to tell You about Your privacy rights and how the law protects You.

We reserve the right to make changes to the Privacy Policy at any time and for any reason. You can familiarize yourself with the current version of the Privacy Policy by following the link.

By using this Platform, you confirm that:

(I) You have read, understood and agree to this Privacy Policy;

(II) You have reached the age from which the legislation of the country of your stay allows you to give your Consent to the Processing of Your Personal Data. In any case, in order to use the Platform, you must be at least 16 years old or one of your legal representatives or guardians has read and agreed to the terms of this Policy on behalf of you. If you do not agree or cannot confirm the above, you must immediately stop using the Platform. 

In this case, you must:

(a) contact Us and request the deletion of Your Data; 

(b) leave the Platform and not use it.

Content of the Policy:

  1. Definitions
  2. Types of Data We Process
  3. Principles of Personal Data Processing We adhere to
  4. Purposes of Personal Data Processing
  5. Legal basis for Processing Your Personal Data
  6. Disclosure of Your Personal Data
  7. How long do we keep Your Personal Data
  8. Your privacy rights under the national legislation of Ukraine
  9. Your privacy rights under GDPR and UK GDPR
  10. Use of Cookies
  11. Storage and transfer of Personal Data
  12. Third-Party Links
  13. Children’s Privacy
  14. Sending marketing, informational / advertising materials to the User
  15. Additional information for Swiss residents
  16. Additional information for California residents
  17. Additional information for Nevada residents
  18. Additional information for residents of Canada
  19. Additional information for UAE residents
  20. Additional information for residents of Israel
  21. Governing law and dispute resolution
  22. Updates of Policy
  23. Contact Us
  1. DEFINITIONS

For the purposes of this Privacy Policy, the words with a capitalized initial letter have meanings defined under the following conditions. Any use of the below definitions or other words in the singular, plural, capitalization and/or he/she or they are taken as interchangeable and therefore as referring to the same.

“DOMOVA” means DOMOVA LLC and its affiliates and subsidiaries, registration number 45200376, registered at Ukraine, 65014, City of Odesa, 16 Kanatna Street, unit 27 (hereinafter referred to as the “Company”, “DOMOVA”, “We”, “Our” or “Us”). 

“Platform” means the website domova.com, all its content and links to this website (hereinafter referred to as the “Platform”, “Website” or “Portal”).  

“Services” — means the services provided by the Company through the Platform, which mainly include information and consulting services for two types of users, which We refer to as “Sellers” and “Buyers” in the process of resettlement of residential and non-residential units in the Objects for Resettlement.

“Account” – User account of one of two types: Seller or Buyer, registered on our Platform for the purpose of fully utilizing our Services. 

“Request” – refers to a formal request that a Seller/Buyer submits on a Platform in order to get Our Services.

“Seller” means a User who has completed the registration process, has an Account, is the Owner or an authorized representative of the Owner of a residential and/or non-residential units, or a share in such units in the object for resettlement and/or a private house, a share in a private house and may submit a request for sale by filling out a special form.

“Buyer” – a User who has completed the registration process, has an Account, can view the Information about the residential property for the Buyer available on Our Platform using two types of viewing: map view and list view, submit a buy request by filling in its proposed price per square meter of such residential property, and may use the following additional tools: comparison, favorites.

“Owner” means an individual or legal entity that is the legal owner of a residential and/or non-residential units, or a share in such units in the Object for Resettlement and/or a private house, or a share in a private house.

“Sale Request” means a request that the Platform receives from You after filling out a formal application consisting of a list of mandatory and optional fields to be filled in. 

“Buy Request” means a request that the Platform receives from the Buyer after filling out a formal application, which includes the field “Proposed price per Square Meter” and a free-text comment, indicates the Buyer’s interest in a particular Object for Resettlement and exists to transfer such information to Our Representative for further negotiations. 

“Consent” – means any freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.

“Personal Data” – any information that relates to an identified or identifiable individual.

“Controller” – means the Company which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

“Processor” – means a Company which Processes Personal Data on behalf of the Controller. 

“Data Subject” or “User” – an identifiable natural person, a visitor who uses the Platform for personal purposes, who can be identified, directly or indirectly in particular by reference to specific identifiers (also referred to as “You”, “Your”).

“Processing of Personal Data” – means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

“European Union”, “EU” — unless otherwise stated, all references to the European Union and the European Economic Area made in this Privacy Policy refer to all present members.

“Third Party” – a legal entity, public authority, agency, or body other than the Data Subject, the Controller, the Processor, and individuals authorized to process Personal Data under the direct supervision of the Controller or the Processor, which other services integrated into the Platform, and individuals who may receive any information from the Platform, including the Company’s partners. The Privacy Policy contains additional information regarding the definitions in this paragraph.

“GDPR” – General Data Protection Regulation of the European Parliament and Council No. 2016/679 of 27.04.2016 on the protection of natural persons in connection with the processing of Personal Data and free movement of such data, and cancellation of Directive 95/46/EC.

“UK GDPR” – regulation included in the United Kingdom and Northern Ireland legislation with changes made in accordance with the Data Protection, Privacy, and Electronic Communications Regulations.

“CCPA” – California Consumer Privacy Act of 2018, a state statute intended to enhance privacy rights and consumer protection for residents of California, United States.

“CalOPPA” – California Online Privacy Protection Act of 2003.

“Ukrainian National Law” – The Law of Ukraine “On Protection of Personal Data” and any other legislation related to the protection of personal data in Ukraine.

  1. TYPES OF DATA WE PROCESS

Personal Data

While registering and using Our Platform, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Data, User provide Us while registering an Account:

  • First name and last name;
  • Phone number;
  • Email address.

Data, Seller provide Us while submitting a Sale Request:

  • Owner’s details such as last name, first name, patronymic;
  • Owner’s registration number of the taxpayer’s identification card;
  • Owner’s/representative’s contact phone number;
  • Owner’s unit full address such as settlement name, street name, house number, unit type (residential, non-residential, private house), unit number for residential and non-residential units. We are incorporating the possibility that, upon providing the specified data, we can immediately collect the coordinates of your house through automated means;
  • Specific parameters, such as the availability of adjacent objects, the condition of the house, its status as a cultural heritage site, full or partial ownership of the unit, the total area of the unit, and the basis of ownership;
  • Desired sale price in US dollars;
  • Additional information stated in the “Comment” field.

Data, Buyer provide Us while submitting a Buy Request:

  • The proposed price per square meter;
  • Additional information stated in the “Comment” field.

Please note that all additional information, stated in the “Comment” field, may be considered as Personal Data. We hereby waive liability for truthfulness and completeness for all additional information, stated in the “Comment” field. The User hereby confirms that he/she provides such Personal Data on a voluntary basis.

We recognize that another person may register an Account in the Seller’s or Buyer’s best interests, and that another person may submit a Request on the Seller’s or Buyer’s behalf. In such case, the applicant accepts full responsibility for the Third Party’s Personal Data that is transferred and verifies the Seller’s or Buyer’s approval to register such an Account and submit a Request. We do not take responsibility for unlawful actions of third parties towards other third parties.

Usage Data

Usage Data is collected automatically when You use the Platform and may include information such as: 

  • type of device/mobile device You use;
  • your operating system/mobile operating system, unique device identifiers, and other diagnostic data (e.g., display ratio and resolution etc.);
  • browser type and browser version;
  • pages of Our Platform that You have visited; 
  • time and date of Your visit;
  • time spent on those pages.
  1. PRINCIPLES OF PERSONAL DATA PROCESSING THAT WE ADHERE TO

DOMOVA adheres to the worldwide principles of Personal Data protection as envisaged in the Ukrainian National Law, EU GDPR and the UK GDPR, CalOPPA, CCPA, and other applicable laws.

 In accordance with these principles, We assure You that the User’s Personal Data is:


– Processed fairly and lawfully and transparently in relation to the Data Subject;
– Processed for specified, explicit, and legitimate purposes only and not further processed in a manner that is incompatible with those purposes;
– Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
– Kept accurate and up to date;
– Retained in a form permitting identification of Data Subjects for no longer than is necessary for the purposes for which they are processed;
– Processed in a manner that ensures their appropriate security;
– Not internationally transferred without an adequate level of protection.

  1. PURPOSES OF PERSONAL DATA PROCESSING

– Provide and maintain Our Platform, including monitoring the usage of Our Platform;

– Personalize and improve User experience;

– Development and maintenance of the security of the Platform. We monitor malfunctions of the Platform and create software solutions to eliminate them, detect violations of the DOMOVA Platform Terms of Use and this Privacy Policy, as well as monitor the use, abuse and potential abuse of the Platform;

– Contact You: We can contact You by email in order to provide You with news, special offers, surveys, critical updates, confirmations, security alerts, and general information about Our Services based on Your previous experience and activity on Our Platform. We may also contact you at the provided phone number to clarify details of the submitted application, provide technical support, and in other necessary cases not related to marketing or advertising activities;

– Provide You with customer support. We Process Your Personal Data when You contact Our support team with questions about or issues with Your Account.

– For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, in which Personal Data held by Us about Our Service Users is among the assets transferred.

– For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving Our Service, marketing, and Your experience.

Personal Data collected from Users may be put through algorithms to make decisions about User experiences, create and assign User profiles, and provide other Services. No algorithms shall be used to make adverse decisions about Users unless it is to fulfill an affirmative duty to prevent criminal activity.

  1. LEGAL BASIS FOR PROCESSING OF PERSONAL DATA

We may Process Personal Data under the following conditions:

Your Consent: You have given Your Consent for Processing Personal Data for one or more specific purposes.

Performance of a contract: Processing of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

Legal obligations: Processing of Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

Vital interests: Processing of Personal Data is necessary in order to protect Your vital interests or of another natural person.

Public interests: Processing of Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

Legitimate interests: Processing of Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help clarify the specific legal basis that applies to the processing, particularly whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter into a contract.

  1. DISCLOSURE OF YOUR PERSONAL DATA

We may disclose Your Personal Data as described below.

    • Third-Party Service Providers. We may share Your Personal Data with third-party service providers to provide technical infrastructure services; conduct quality assurance testing; analyze how Our Platform is used; prevent, detect, and respond to unauthorized activities; provide technical and customer support; and/or provide other support to Us and to the Platform. We can also use Third Parties widgets on Our Platform, which extend its functionality. Please note, that after You are redirected to Third Parties’ website, Your Personal Data will be processed according to Third Parties’ own privacy policy.
    • Affiliates. We may share some or all of Your Personal Data with any subsidiaries, joint ventures, or other companies under Our common control (“Affiliates”), in which case We will require Our Affiliates to honor this Policy.
    • Corporate Restructuring. We may share some or all of Your Personal Data in connection with or during the negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of Our business or assets. In the event of insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires Our Company, business, or assets, that company will possess the Personal Data collected by Us and will assume the rights and obligations regarding Your Personal Data as described in this Policy.
    • Legal Rights. Regardless of any choices You make regarding Your Personal Data (as described below), DOMOVA may disclose Personal Data if it believes in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, warrants, or other legal process served on DOMOVA; (c) to protect or defend the rights or property of DOMOVA or Users of the Portal; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Policy, or Our Terms of Use.
  • Other Disclosures. We may also disclose Your Personal Data: to fulfill the purpose for which You provide it; for any other purpose disclosed by Us when You provide it; or with Your Consent.

Our Platform uses Google Analytics, Meta Pixel, and other web analytics services to compile reports on visitor usage and to help Us improve Our Platform. For an overview of Google Analytics, please visit https://www.google.com/analytics/. You can opt out of Google Analytics with this browser add-on tool: https://tools.google.com/dlpage/gaoptout. For an overview of Meta Pixel, please visit 

https://developers.facebook.com/docs/meta-pixel/.   

Please note that the data collected by Google and Meta is being transmitted to the United States of America. 

To learn how Google LLC. Processes Your Personal Data, visit:

https://policies.google.com/privacy. 

To learn how Meta Platforms Inc. Processes Your Personal Data, visit:

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

  1. HOW LONG DO WE KEEP YOUR PERSONAL DATA

 We keep Your Personal Data only for as long as We need to, in accordance with the processing purposes as stated in the section “Purposes of Personal Data Processing” and applicable legislation. This time period may depend on what We use Your information for, per this Privacy Policy. For example, if You have provided Us with Personal Data as part of creating an Account on the Platform, We may retain this information for the duration Your Account exists on Our Platform. If Your Personal Data is no longer required for this purpose, We will delete it or make it anonymous by removing all details that identify You, after the expiration of twelve months since Your Account was deleted.

However, if necessary, We may retain Your Personal Data for Our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes.

  1. YOUR PRIVACY RIGHTS UNDER THE NATIONAL LEGISLATION OF UKRAINE:

The Data Subject has the right to:

1) to know about the sources of collection, location of his/her Personal Data, the purpose of their processing, location or place of residence (stay) of the Controller or the Processor of Personal Data or to give a corresponding order to obtain this information to persons authorized by them, except in cases established by law;

2) to receive information on the conditions for granting access to Personal Data, including information about third parties to whom his/her Personal Data is transferred;

3) to have access to his/her Personal Data;

4) to receive a response on whether his/her Personal Data is processed no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, and to receive the content of such Personal Data;

5) to submit a reasoned request to the Controller with an objection to the processing of his/her Personal Data;

6) to submit a reasoned request to change or destroy his/her Personal Data by any Controller or the Processor of Personal Data, if such data is processed illegally or is unreliable;

7) to protect their Personal Data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is inaccurate or discrediting the honor, dignity, and business reputation of an individual;

8) file complaints against the processing of their Personal Data with the commissioner or the court;

9) apply for legal remedies in case of violation of the legislation on Personal Data protection;

10) to make reservations regarding the restriction of the right to process their Personal Data when giving consent;

11) withdraw consent to the processing of Personal Data;

12) to know the mechanism of automatic processing of Personal Data;

13) to be protected against an automated decision that has legal consequences for him/her.

9. YOUR PRIVACY RIGHTS UNDER GDPR & UK GDPR

We undertake to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights, described below:

– Right of access to Your Personal Data. You can access, update, or request the deletion of Your Personal Data. If You are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

– Right to request rectification of Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.

– Right to restriction of Processing of Personal Data. This right allows data subjects to request the temporary limitation of the processing of their personal data under certain circumstances.

– Right to object to Processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing, and there is something about Your particular situation which makes You want to object to Our Processing of Your Personal Data on this ground. You also have the right to object where We are Processing Your Personal Data for direct marketing purposes.

– Right to request the erasure of Your Personal Data (“right to be forgotten”). You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

– Right to request the transfer of Your Personal Data (“right to data portability”). We will provide to You, or a Third Party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided Consent for Us to use, or where We used the information to perform a contract with You.

– Right to withdraw Your Consent. You have the right to withdraw Your Consent to the use of Your Personal Data. If You withdraw Your Consent, We may not be able to provide You with access to certain specific functionalities of the Platform.

– Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning You or similarly significantly affects You.

You may exercise Your rights by contacting Us at [email protected]. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try Our best to respond to You as soon as possible, but not later than 30 (thirty) days from receiving Your request.

You have the right to complain to a data protection authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA. 

Citizens of the UK also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. For further information about Your rights, please contact the Information Commissioner’s Office (ICO).

10. USE OF COOKIES

 

We use “cookies” to collect information about You and Your activity across Our Platform. A cookie is a small piece of data that our Platform stores on Your computer, or other device, and accesses each time You visit, so We can understand how You use Our Platform. This helps Us serve Your content based on the preferences You have specified.

 

Please refer to Our Cookie Policy for more information.

  1. STORAGE AND TRANSFER OF PERSONAL DATA

All Personal Data that We hold about You will be stored on Hetzner Online GmbH servers. For more information about Hetzner Online GmbH privacy policy, please visit https://www.hetzner.com/legal/privacy-policy . We reserve the right to implement a more complex system for the protection of your personal data and documents, and to not disclose information about the servers and the implementation and operation algorithm of such a system.

The countries to which We transfer Your Personal Data may not have the same data protection laws as the country in which You initially provided Data. If We transfer Your Personal Data to Third Parties in other countries: (i) We will perform those transfers in accordance with the requirements of applicable law; and (ii) We will protect the transferred Personal Data in accordance with this Privacy Policy.

 We will only transfer Users’ Personal Data to contractors and subcontractors, Processors, and sub-processors that We have confidence in. We carefully choose partners to ensure that the User’s Personal Data is processed in accordance with current privacy legislation.

 Furthermore, We may outsource particular operations to Third Parties and, consequently, transfer Your Personal Data to Our IT systems providers, website hosting providers, data analysis, data backup, security and cloud storage services, consultants, and other providers. We only share Personal Data that they reasonably need to provide their services and will not transfer Your Personal Data to any Third Parties for their own direct marketing purposes. Likewise, We ensure that third-party service providers are authorized to use Your Personal Data only as necessary to provide services on Our behalf or in Our interest.

While storing Your Personal Data outside Ukraine, We will take all commercially reasonable measures to prevent unauthorized access to your Personal Data and those data obtained in the process of using the Platform. We strive to protect Your Personal Data by various means in order to preserve its confidentiality and integrity, prevent unauthorized use or disclosure of your Personal Data, and protect your Personal Data from loss, misuse, disclosure, alteration and/or destruction. 

Please note that no method of data transmission over the Internet can provide a 100% guarantee of preventing information leakage. In the event of such a leak, we undertake the obligation to notify about this fact by publishing a press release on our portal or our official pages on social media.

  1. THIRD-PARTY LINKS

 We may place advertisement banners or other types of hyperlinks on Our Platform, interacting with which may redirect You to the Third-Party website.

In the event Our Platform contains links to Third-Party sites and services, please be aware that those sites and services have their own privacy policies. Please be aware that We have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices. After following a link to any third-party content, You should read their posted privacy policy information about how they collect and use Personal Data. This Privacy Policy does not apply to any of Your activities after You leave Our Platform.

  1. CHILDREN’S PRIVACY

We do not aim any of Our Services directly at children under the age of 16, or the lower legal age of majority where You reside, and We do not knowingly Process Personal Data about children under 16, or the lower legal age of majority in Your jurisdiction.

 If You are under the age of 16 or under the legislation of majority where You reside You are considered a child and have provided Personal Data on the Platform, You hereby warrant that You have the right to do so under applicable law and, where such law requires, that You have obtained the prior consent of one of Your parents. DOMOVA hereby disclaims all liability if such permission has not been obtained.

Parents and guardians are encouraged to teach minors to exercise responsibility and caution when it comes to providing their Personal Data over the Internet.

  1. SENDING MARKETING, INFORMATIONAL / ADVERTISING MATERIALS TO THE USER

From time to time, with the User’s prior consent, We may send marketing, informational/advertising messages and materials regarding the Company’s activities, including commercial offers, announces about new Services, to the User’s email address.

Consent to receive such messages is given by the User by checking the checkbox indicating consent to this Privacy Policy and/or by putting the appropriate mark in the checkbox to the corresponding form on the Platform, which confirms the User’s will to receive such messages and materials.

In other case We will not send marketing, informational / advertising messages and materials regarding the Company’s activities, including commercial offers, announces about new Services to the User, but will only communicate with the User regarding his specific request.

If the User has agreed to receive marketing, informational / advertising messages and materials regarding the Company’s activities, including commercial offers, announces about new Services, such messages and materials will be sent by Us for any reason that We consider to be in the User’s interests.

At the same time, the User has the right to withdraw the Consent for the further receipt of the above-mentioned materials by submitting an appropriate objection to their receipt by contacting Us at the e-mail address: [email protected].

  1. SUPPLEMENTAL NOTICE FOR SWISS RESIDENTS

If You are a resident of Switzerland, We inform You that DOMOVA Process Your Personal Data in accordance with the Federal Act on Data Protection (FADP) 1992.

In addition to the rights You may find, respectively, in the section “Your rights under GDPR & UK GDPR” above, You also have other rights under FADP, especially to access Your Personal Data, that We hold, and ask for free copies of such Data.

If You believe that We have breached a relevant data protection law and wish to make a complaint, please contact Us using the details below and provide Us with full details of the alleged breach. We will promptly investigate Your complaint and respond to You in writing, setting out the outcome of Our investigation and the steps We will take to deal with Your complaint. You also have the right to contact a regulatory body or data protection authority in relation to Your complaint.

 You have the right to complain to the Federal Data Protection and Information Commissioner (FDPIC) as the federal data regulator in Switzerland, about Our collection and use of Your Personal Data. For more information, if You are in Switzerland, please contact FDPIC.

We may refuse, restrict or delay the provision of information if required by law or in order to protect the interests of Third Parties.

We take all necessary security measures to prevent any unauthorized or illegal Processing of Personal Data, as well as intentional or accidental loss, damage, or destruction of Personal Data, technical errors, falsifications, theft, and illegal use, unauthorized access, alteration, copying or other forms of unauthorized processing.

  1. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental California Privacy Notice only applies to Our Processing of Personal Data that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of Personal Data DOMOVA has collected about them and whether We have disclosed that Personal Data for a business purpose (e.g., to a service provider) in the preceding 12 months. The categories of sources from which We collect Personal Data and Our business and commercial purposes for using Personal Data are set forth in “Personal Data We Process” and “How We Use Your Personal Data” above, respectively. 

“Sales” of Personal Data under the CCPA

For purposes of the CCPA, DOMOVA does not “sell” Personal Data, nor do We have actual knowledge of any “sale” of Personal Data of minors under 16 years of age.

Opt-out of “Sales”. California’s residents may opt out of the “sale” of their Personal Data by contacting Us at: [email protected].

Additional Privacy Rights for California Residents:

Non-Discrimination. California’s residents have the right not to receive discriminatory treatment by Us for the exercise of their rights conferred by the CCPA. 

Authorized Agent. Only You, or someone legally authorized to act on Your behalf, may make a verifiable consumer request related to Your Personal Data. You may also make a verifiable consumer request on behalf of Your minor child. To designate an authorized agent, please contact Us at: [email protected] and provide written authorization signed by You and Your designated agent.

Verification. To protect Your privacy, We will take the following steps to verify Your identity before fulfilling Your request. When You make a request, We will ask You to provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Data or an authorized representative, which may include asking You to answer questions, for example, regarding Your name and email address.

If You are a California resident and would like to exercise any of Your rights under the CCPA, please contact Us at: [email protected]. We will process such requests in accordance with applicable laws. 

Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If You wish to print this policy, please do so from Your web browser or by saving the page as a PDF. 

California Shine the Light law. California “Shine the Light” law permits Users who are California residents to request and obtain from Us once a year, free of charge, a list of the Third Parties to whom We have disclosed their Personal Data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Data disclosed to those parties.

Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting Us at: [email protected].

  1. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If You are a resident of Nevada, You have the right to opt-out of the sale of certain Personal Data to Third Parties who intend to license or sell that Personal Data. You can exercise this right by contacting Us at: [email protected] with the subject line “Nevada Do Not Sell Request” and providing Us with Your name and the email address associated with Your Account.  Please note that We do not currently sell Your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A. If You have any questions, please contact Us as set forth below.

  1. ADDITIONAL INFORMATION FOR RESIDENTS OF CANADA

This section applies only to residents of Canada. The Company processes Personal Data in accordance with the Law “On the Protection of Personal Information and Electronic Documents” (hereinafter – “PIPEDA”).

In addition to the rights listed in section 8 of this Policy, You also have the right to submit a request to Us to find out what Personal Data We collect, the right to withdraw Your Consent to the Processing of Personal Data, the right to challenge Our compliance with the provisions of PIPEDA to the Office of the Ombudsman of Canada (OPC).

In order to submit a request regarding exactly which of Your Personal Data We Process, please contact Us at: [email protected]. In case of receiving your request for access to Personal Data, We will try to respond as soon as possible, but no later than 30 (thirty) days from the date of receipt of the request.

We have the right to extend the 30-day period for providing an answer to the request for another 30 (thirty) days in the event that:

  • providing a response within the initial 30 (thirty) days may be considered unreasonable interference in Our activities;
  • We need additional time for consultations;
  • We need additional time to convert Personal Data into a readable format.
  • You have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC) if we do not respond to your request within the first 30 days.

In the event of a leak of Your Personal Data, We will promptly notify You of such a case and the degree of threat to Your Personal Data. In accordance with PIPEDA, We will immediately notify the Office of the Privacy Commissioner of Canada (OPC) and keep a record of the leak that has occurred.

We may disclose Personal Data to third-party service providers and related corporations located outside of Canada for the purposes set forth in this Privacy Policy. The Company’s policy requires that the Company share your Personal Data abroad in a manner that requires the highest standards of confidentiality and security when transporting Personal Data abroad. Please note that when Personal Data is transferred abroad, it may be accessed by courts, law enforcement agencies, and national security agencies. Before disclosing Personal Data, We will assess possible risks that may adversely affect the protection of Personal Data. We ensure the appropriate level of integrity and protection of Personal Data when transferred to third parties, which is required by the provisions of PIPEDA, by entering into agreements with such companies, which provide for the limitation of the use of Personal Data by the Third Party solely for the purposes provided for in the agreement.

  1. SUPPLEMENTAL NOTICE FOR UAE RESIDENTS

Legal Basis for Processing of Personal Data:

We may process Personal Data under the following conditions:

  • Consent: You have given Your Consent for Processing Personal Data for one or more specific purposes.
  • Vital interests: Processing of Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing of Personal Data is related to a task that is carried out in the public interest or the exercise of official authority vested in the Company.
  • Legitimate interests: Processing of Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
  • To claim legal rights or as part of judicial or security procedures;
  • For the Data Controller’s compliance with legal obligations; or
  • Any other circumstances specified by the Executive Regulations issued under the PDPL.

In any case, the Company will gladly help clarify the specific legal basis that applies to the processing, particularly whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter into a contract.

Your Rights under the UAE Federal Decree Law No. 45/2021 on the Protection of Personal Data:

 

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

In addition to the rights You may find, respectively, in the section “Your rights under GDPR & UK GDPR” above, You also have other rights under UAE Federal Decree Law No. 45/2021 on the Protection of Personal Data Rights if You are within the UAE.

Exercising of Your UAE Federal Decree Law No. 45/2021 on the Protection of Personal Data Rights:

 

You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try Our best to respond to You as soon as possible.

Complaints. If You believe that We have breached a relevant data protection law and wish to make a complaint, please contact Us using the details below and provide Us with full details of the alleged breach. We will promptly investigate Your complaint and respond to You in writing, setting out the outcome of Our investigation and the steps We will take to deal with Your complaint. You also have the right to contact a regulatory body or data protection authority in relation to Your complaint.

 

You have the right to complain to the UAE Data Office, as the federal data regulator in the UAE, about Our collection and use of Your Personal Data. For more information, if You are in the UAE, please contact the UAE Data Office.

Non-discrimination. We will not discriminate against You for exercising any of Your rights over Your Personal Data. Unless Your Personal Data is required to provide You with a particular Service or offer (for example, providing user support), We will not deny You Services and/or charge You different prices or rates for Services, including through granting discounts or other benefits, or imposing penalties, or provide You with a different level or quality of Services.

 

Notification of data breaches. We will comply with laws applicable to Us regarding any data breach.

 

Unsubscribe. To unsubscribe from Our email database or opt-out of communications (including marketing communications), please contact Us using the details provided in this Privacy Policy or the opt-out facilities provided in the communication. We may request specific information from You to help Us confirm Your identity.

International Transfers Outside the UAE:

We will ensure that any transfer of Personal Data from the UAE to other countries will be compliant in accordance with approval by the Data Office as having an “adequate level of protection.” 

The cross-border transfer of Personal Data to inadequate countries can also be done in the following circumstances:

  • Under a contract that applies the requirements of the PDPL (standard contract clauses);
  • After obtaining the Data Subject’s express Consent for such transfer;
  • If the transfer is necessary for the execution of a contract between the Controller and the Data Subject or as part of a contract between the Controller and a Third Party that achieves the interests of a Data Subject;
  • If the transfer is necessary for international judicial cooperation;
  • If the transfer is necessary to protect the public interest.

 

  1. ADDITIONAL INFORMATION FOR RESIDENTS OF ISRAEL 

This section applies only to residents of Israel. The Company processes Personal Data in accordance with the Israel Law “On confidentiality protection” № 5741-1981 and corresponding laws and regulations having the data transition and security as its subject of matter.

In addition to the rights listed in Section 8 of this Policy, You also have the right to review Your Personal Data We Process. For this, please contact Us at: [email protected].

Your access to Personal Data may be subject to certain restrictions, and We may redact certain information from the copy of the relevant files provided to You to protect trade secrets and business information belonging to Us and/or any third party with respect to whom We have an obligation of confidentiality by deed or law, and confidentiality of any subject of Personal Data.

If, after reviewing Your Personal Data that We Process, You believe that such Data is inaccurate, incomplete, or incorrect, You may contact Us at: [email protected]  and request correction or deletion of Personal Data. We reserve the right, after accepting your request, to approve or reject it in accordance with applicable law. We will notify you of our decision in any case no later than 30 (thirty) days after receiving your request.

Furthermore, we may disclose Personal Data to third party service providers and related corporations located outside of Israel for the purposes set forth in this Privacy Policy. The Company’s policy requires that the Company share your Personal Data abroad in a manner that requires the highest standards of confidentiality and security when transporting Personal Data abroad.

  1. GOVERNING LAW AND DISPUTE RESOLUTION

This Privacy Policy shall be governed and construed in accordance with the laws of Ukraine, without regard to conflict of laws principles or provisions. All disputes that may arise in the course of or in connection with the Privacy Policy shall be resolved by the negotiations. 

If a User has a potential legal dispute, claim, or cause of action against DOMOVA, the User shall first (prior to initiating any proceedings) contact DOMOVA by sending an email to the email address listed in the “Contact Us” section of this Privacy Policy describing the nature of the potential dispute, claim, or cause of action and providing all relevant documentation and evidence thereof. Users shall use their respective reasonable endeavor to settle any dispute, difference claim, question, or controversy arising out of, in connection with, or in relation to this Privacy Policy amicably through negotiations in good faith.

  1. UPDATES OF POLICY

We reserve the right to change, supplement, or otherwise amend these Terms at any time and without any liability as a result. The most current version of this Privacy Policy will be posted on the Platform with the date of such version. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy. In the event that the User does not agree with any such modification, the User’s sole and exclusive remedy is to terminate the use of the Platform and close the Account.

  1. CONTACT US

For any questions or concerns regarding Your privacy, You may contact Us using the following details:

DOMOVA LLC

Address: Ukraine, 65014, City of Odesa, 16 Kanatna Street, unit 27

Registration number: 45200376

Email: [email protected] 

After We receive Your request for access to Personal Data or complaint, We will try to respond as soon as possible, but not later than 30 (thirty) days (or quicker if it’s necessary for Your jurisdiction) from the date of receipt of such request.

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