Welcome to DOLA’s Privacy Policy
- Hi there, we’re DOLA Pty Ltd (ABN 11 119 159 741) of Level 1, 121 King Street
Melbourne, 3000, Australia (“DOLA”) and welcome to our privacy policy
which also applies to our Affiliate Companies. This policy sets out how we handle your
personal information if you’re an DOLA user or visitor to our Sites. It applies across
DOLA Elements, DOLA Market, DOLA Twenty20, DOLA Studio, DOLA Sites, DOLA
Tuts+ and Placeit (the “Sites”).
- When we say ‘we’, ‘us’ or ‘DOLA’ it’s because that’s who we are and we own and run the
Sites.
- If we say ‘policy’ we’re talking about this privacy policy. If we say ‘user terms’ we’re
talking about the rules for using each of the Sites. The rules vary by product and each
product makes them separately available and seeks consent to them separately to this
policy.
The type of personal information we collect
- We collect certain personal information about visitors and users of our Sites.
- The most common types of information we collect include things like: user-names, member
names, email addresses, IP addresses, other contact details, survey responses, blogs,
photos, payment information such as payment agent details, transactional details, tax
information, support queries, forum comments (if applicable), content you direct us to
make available on our Sites (such as item descriptions), your actions on our Sites
(including any selections or inputs into items) and web and email analytics data. We
will also collect personal information from job applications (such as, your CV, the
application form itself, cover letter and interview notes).
How we collect personal information
- We collect personal information directly when you provide it to us, automatically as you
navigate through the Sites, or through other people when you use services associated
with the Sites.
- We collect your personal information when you provide it to us when you complete
membership registration and buy or provide items or services on our Sites, subscribe to
a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send
us a communication.
- As the operator of digital content marketplaces, we have a legitimate interest in
verifying the identity of our authors. We believe that knowing who our authors are will
strengthen the integrity of our marketplaces by reducing fraud, making authors more
accountable for their content and giving DOLA and customers the ability to enforce
contracts for authors who break the rules. DOLA also has certain legal obligations
that require us to know who our authors are in certain circumstances. In light of this,
if you are an author we will verify your identity, in particular, your name, full
address and date of birth by asking you to show us a Photo ID document. The verification
procedure is called DOLA Verify. DOLA Verify will be carried out by our service
provider Jumio Corporation located at 395 Page Mill Road, Suite 150, Palo Alto,
California, USA. As part of DOLA Verify, you will be asked to take a selfie which will
then be compared against your Photo ID document using facial recognition technology. We
will use your Photo ID document solely to carry out DOLA Verify and delete it after
the completion of this process.
Personal information we collect about you from others
- Although we generally collect personal information directly from you, on occasion, we
also collect certain categories of personal information about you from other sources. In
particular:
- financial and/or transaction details from payment providers located in the US,
UK, and Australia in order to process a transaction;
- third party service providers (like Google, Facebook) who are located in the US
or UK, which may provide information about you when you link, connect, or login
to your account with the third party provider and they send us information such
as your registration and profile from that service, this only occurs if you are
using DOLA Studio. The information varies and is controlled by that service
provider or as authorized by you via your privacy settings at that service
provider; and
- other third party sources/and or partners from Australia, US or UK, whereby we
receive additional information about you (to the extent permitted by applicable
law), such as demographic data or fraud detection information, and combine it
with information we have about you. For example, fraud warnings from service
providers like identity verification service. We also receive information about
you and your activities on and off the DOLA platform through partnerships, or
about your experiences and interactions from our partner ad networks. We also
receive information about you as a rights holder from our third party authors.
For example, information in the form of a model release when your image is used
in an item made available on our Sites.
How we use personal information
- We will use your personal information:
- To fulfil a contract, or take steps linked to a contract: in particular, in
facilitating and processing transactions that take place on the Sites, like
where you purchase an item from our marketplace.
- Where this is necessary for purposes which are in our, or third parties’,
legitimate interests. These interests include:
- operating the Sites;
- providing you with services described on the Sites;
- verifying your identity when you sign in to any of our Sites;
- responding to support tickets, and helping facilitate the resolution of
any disputes;
- updating you with operational news and information about our Sites and
services e.g. to notify you about changes to our Sites, website
disruptions or security updates;
- carrying out technical analysis to determine how to improve the Sites
and services we provide;
- monitoring activity on the Sites, e.g. to identify potential fraudulent
activity and to ensure compliance with the user terms that apply to the
Sites;
- managing our relationship with you, e.g. by responding to your comments
or queries submitted to us on the Sites or asking for your feedback or
whether you want to participate in a survey;
- managing our legal and operational affairs (including, managing risks
relating to content and fraud matters);
- training DOLA staff about how to best serve our user community;
- improving our products and services;
- providing general administrative and performance functions and
activities; and
- verifying your identity by comparing a selfie taken by you against your
Photo ID document using facial recognition technology (as is necessary
for the establishment, exercise or defense of legal claims); and
- processing your job application to DOLA.
- Where you give us consent:
- providing you with marketing information about products and services
which we feel may interest you; and
- customising our services and websites, like advertising that appear on
the Site – where this involves the use of cookies or similar
technologies – in order to provide a more personalised experience.
- For purposes which are required by law.
- For the purpose of responding to requests by government, a court of law, or law
enforcement authorities conducting an investigation.
When we disclose your personal information
- We will disclose personal information to the following recipients:
- companies that are in the DOLA group which are located in Australia, Mexico
and the US;
- if applicable, authors of any items or services made available to you, so they
can facilitate support and license validation, who maybe located in any of the
countries our products are available in;
- subcontractors and service providers who assist us in connection with the ways
we use personal information (as set out above), in particular: website hosting
providers which are located in Australia, US and UK; technical and customer
support services which are located in Australia, Canada, Philippines, Poland,
Mexico, Romania, UK and the US; recruitment agencies which are located in
Australia, US and Mexico; marketing and analytics services which are located in
the US; security and fraud prevention services which are located in the US;
subscription management services which are located in the US; payment processing
services which are located in the US, UK and Australia; identification
verification services located in the UK; and operational tooling services which
are located in the US. Noting that our subcontractors and services providers may
also transfer and access such information from other countries in which they
have operations.
- our professional advisers (lawyers, accountants, financial advisers etc.) which
are located in Australia, Ireland, Mexico, UK and USA;
- regulators and government authorities in connection with our compliance
procedures and obligations;
- a purchaser or prospective purchaser of all or part of our assets or our
business, and their professional advisers, in connection with the purchase;
- a third party to respond to requests relating to a criminal investigation or
alleged or suspected illegal activity;
- a third party, in order to enforce or defend our rights, or to address financial
or reputational risks;
- a rights holder in relation to an allegation of intellectual property
infringement or any other infringement; and
- other recipients where we are authorised or required by law, or requests by
government, a court of law, or law enforcement authorities, to do so.
Where we transfer and/or store your personal information
- We are based in Australia and Mexico so your data will be processed in Australia, Mexico
and the US. Some of the recipients we have described in section 10 above, and to whom we
disclose your personal information, are based in places like Australia, Canada, Ireland,
Mexico, Philippines, Poland, Romania, UK, the US, India and Columbia. We do this on the
basis of this policy. In order to protect your information, we take care where possible
to work with subcontractors and service providers who we believe maintain an acceptable
standard of data security compliance.
How we keep your personal information secure
- We store personal information on secure servers that are managed by us and our service
providers, and occasionally hard copy files that are kept in a secure location in
Australia, Ireland, Mexico and the US. Personal information that we store or transmit is
protected by security and access controls, including username and password
authentication, two-factor authentication, and data encryption where appropriate.
How you can access your personal information
- You can access some of the personal information that we collect about you by logging in
to your account. You also have the right to make a request to access other personal
information we hold about you and to request corrections of any errors in that data. You
can also close the account you have with us for any of our Sites at any time. To make an
access or correction request, contact our privacy champion using the contact details at
the end of this policy.
Marketing Choices regarding your personal information
- Where we have your consent to do so (e.g. if you have subscribed to one of our email
lists or have indicated that you are interested in receiving offers or information from
us), we send you marketing communications by email about products and services that we
feel may be of interest to you. You can ‘opt-out’ of such communications if you would
prefer not to receive them in the future by using the “unsubscribe” facility provided in
the communication itself.
- You also have choices about cookies, as described below. By modifying your browser
preferences, you have the choice to accept all cookies, to be notified when a cookie is
set, or to reject all cookies. If you choose to reject cookies some parts of our Sites
may not work properly in your case.
Cookies (not the type you eat!) and web analytics
- For more information about how we use cookies, web beacons and similar technologies see
our cookie policy here and for more general
information on cookies, see http://www.allaboutcookies.org.
- When you visit our Sites, there’s certain information that’s recorded which is generally
anonymous information and does not reveal your identity. If you’re logged into your
account some of this information could be associated with your account. We’re talking
about the following kinds of details:
- your IP address or proxy server IP address’;
- the domain name you requested;
- the name of your internet service provider is sometimes captured depending on
the configuration of your ISP connection;
- the date and time of your visit to the website;
- the length of your session;
- the pages which you have accessed;
- the number of times you access our site within any month;
- the file URL you look at and information relating to it;
- the website which referred you to our Sites;
- the operating system which your computer uses; and
- the technical capabilities of your web browser.
- Occasionally, we will use third party advertising companies to serve ads based on prior
visits to our Sites. For example, if you visit our Sites, you may later see an add for
our products and services when you visit a different Site. Read more about your options
in our cookie policy.
Information about children
- Our Sites are not suitable for children under the age of 16 years, so if you are under
16 we ask that you do not use our Sites or give us your personal information (if you are
a young tech wiz, please direct your nearest responsible adult to use the Sites for
you!). If you are from 16 to 18 years, you can browse the Sites but you’ll need the
supervision of a parent or guardian to become a registered user. It’s the responsibility
of parents or guardians to monitor their children’s use of our Sites.
Information you make public or give to others
- If you make your personal information available to other people, we can’t control or
accept responsibility for the way they will use or manage that data. There are lots of
ways that you can find yourself providing information to other people, like when you
post a public message on a forum thread, share information via social media, or make
contact with another user (such as a third party Author) whether via our Sites or
directly via email. Before making your information publicly available or giving your
information to anyone else, think carefully. If giving information to another user via
our Sites, ask them how they will handle your information. If you’re sharing information
via another website, check the privacy policy for that site to understand its
information management practices as this privacy policy will not apply.
How long we keep your personal information
- We retain your personal information for as long as is necessary to provide the services
to you and others, and to comply with our legal obligations. If you no longer want us to
use your personal information or to provide you with the DOLA services, you can
request that we erase your personal information and close your DOLA account. Please
note that if you request the erasure of your personal information we will retain
information from deleted accounts as necessary for our legitimate business interests, to
comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot
problems, assist with investigations or requests by government, a court of law, or law
enforcement authorities, enforce the terms of service and take other actions permitted
by law. The information we retain will be handled in accordance with this Privacy
Policy.
When we need to update this policy
- We will need to change this policy from time to time in order to make sure it stays up
to date with the latest legal requirements and any changes to our privacy management
practices.
- When we do change the policy, we’ll make sure to notify you about such changes, where
required. A copy of the latest version of this policy will always be available on this
page.
How you can contact us
- If you have any questions about our privacy practices or the way in which we have been
managing your personal information, please contact our privacy champion in writing at PO
Box 16122 Collins Street West Victoria 8007 Australia or privacy.champion@DOLA.com.
- We’re really glad you made it to the end of the privacy policy, because knowing this
stuff is the best way to understand how your personal information is used and how to
best manage it!
If you’re a user or visitor in the European Economic Area these rights also apply to
you:
- For the purposes of applicable EU data protection law (including the General Data
Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’
of your personal information.
How you can access your personal information
- You are also entitled to ask us to port your personal information (i.e. to transfer in a
structured, commonly used and machine-readable format, to you), to erase it, or restrict
its processing. You also have rights to object to some processing that is based on our
legitimate interests, such as profiling that we perform for the purposes of direct
marketing, and, where we have asked for your consent to process your data, to withdraw
this consent as more fully described below.
- These rights are limited in some situations – for example, we can demonstrate that we
have a legal requirement to process your personal information. In some instances, this
means that we may retain some data even if you withdraw your consent.
- Where we require your personal information to comply with legal or contractual
obligations, then provision of such data is mandatory: if such data is not provided,
then we will not be able to manage our contractual relationship with you, or to meet
obligations placed on us. In all other cases, provision of requested personal
information is optional.
- If you have unresolved concerns you also have the right to complain to data protection
authorities. The relevant data protection authority will be the data protection
authority of the country: (i) of your habitual residence; (ii) of your place of work; or
(iii) in which you consider the alleged infringement has occurred.
Both personal information and personal data have the same meaning in the context of
this Privacy Policy.
Affiliate Companies means DOLA Elements Pty Ltd, DOLA Twenty20 Pty Ltd, DOLA Sites Pty
Ltd, and DOLA Placeit Pty Ltd.
DOLA Privacy Policy v4.3, effective date 17 March 2020
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