Privacy Policy

Introduction

This document refers to personal data, which is defined as information concerning any living person (a natural person) that is not already in the public domain.

This Privacy Policy governs the way Doulos, Ltd (Doulos). collects, uses, maintains and discloses information collected from users (each, a “User” or “Users”, or Data Subject) of the http://www.edaplayground.com website (“Site”).

Doulos is pleased to provide the following Privacy Notice:

Personal Data and how we use it

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, email address. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

Web browser cookies

Our Site may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

How we use collected information

Doulos, may collect and use Users personal information for the following purposes:

  • To improve customer service: Information you provide helps us respond to your customer service requests and support needs more efficiently.
  • To personalize user experience: We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
  • To improve our Site: We may use feedback you provide to improve our products and services.
  • To run a promotion, contest, survey or other Site feature: To send Users information they agreed to receive about topics we think will be of interest to them.
  • To send periodic emails: Users may receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

How we protect your information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.

Sharing your personal information

We do not sell or rent Users personal identification information to others. We may share Users personal information with our business partners if User uses the business partner’s product through our Site. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes.

Third party websites

Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

Advertising

Ads appearing on our Site may be delivered to Users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile non personal identification information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This privacy policy does not cover the use of cookies by any advertisers.

Web hosting providers

Cloudflare manage and secure the traffic to some of the Doulos websites. They will log access in accordance with their security policy ( https://www.cloudflare.com/security-policy/ ) and share aggregated data with us.

Links

This site contains links to other websites. We are not responsible for the privacy practices of these and you should read their own privacy policies. The policy described here, applies only to personal data collected by Doulos.

Legitimate interests pursued by Doulos and/or its clients

To promote the marketing and consulting and training services offered by Doulos and/or to market the services and/or products offered by Doulos’ clients.

Disclosure

Doulos may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. Doulos requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. Some data is passed to parties situated outside the EEA. In this case Doulos will ensure they are part of the EU-US Privacy Shield (if a USA entity) or adhere fully to the requirements of GDPR.

Doulos do not broker or pass on information gained from your engagement without your consent. However, Doulos may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. Doulos may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Doulos, its clients and/or the wider community.

Retention Policy

Doulos will process personal data during the duration of any contract and will continue to store only the personal data needed for ten years after the contract has expired to meet any legal obligations. After ten years any personal data not needed will be deleted.

Data storage

Data is held in the UK and in the USA using different servers. The data held in the USA conforms to the full requirements of GDPR. Data stored in the cloud will be with GDPR compliant suppliers.

Your rights as a data subject

At any point whilst Doulos is in possession of or processing your personal data, all data subjects have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply you have a right to restrict the processing. See The Doulos Opt-Out Policy
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Doulos refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

Doulos at your request can confirm what information it holds about you and how it is processed

You can request the following information:

  • Identity and the contact details of the person or organisation (Doulos) that has determined how and why to process your data.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Doulos or a third party such as one of its clients, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority (Data Protection Regulator).
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access what personal data is held, identification will be required

Doulos will accept the following forms of ID when information on your personal data is requested: a photocopy or scanned image of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Doulos is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to dpo@doulos.com or by writing to us at the address further below.

Changes to this policy

Doulos has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Complaints

In the event that you wish to make a compliant about how your personal data is being processed by Doulos or its partners, you have the right to complain to Doulos’ CEO. If you do not get a response within 30 days you can complain to the Data Protection Regulator.

The details for each of these contacts are:

Doulos, attention of the CEO 22 Market Place, Ringwood, Hampshire, BH24 1AW Telephone +44 1425 471223 or email dpo@doulos.com

Data Protection Regulator (ICO) Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Telephone: +44 303 123 1113 or online messaging: https://ico.org.uk/global/contact-us/email Or email: registration@ico.org.uk

This document was last updated on 24 May 2018