Effective Date 21.11.2022

PRIVACY NOTICE

This Privacy Notice (“Privacy Notice”) explains how information is collected and used by Doingbetter (“we”, “us”, “our”) and its subsidiaries and affiliated companies.
Your privacy is important to us. We encourage you to read this Privacy Notice in its entirety before submitting any information.

TABLE OF CONTENTS
1. Definitions
2. Scope
3. What Personal Information We Collect
4. How We Use Your Personal Information
5. How We Share Your Personal Information
6. Your Choices
7. How Long Do We Store Your Personal Information
8. Security
9. Children’s Information
10. Your Privacy Rights
11. Compliance and Accountability
12. How To Contact Us
13. Changes to Our Privacy Notice

1. DEFINITIONS
The following terms shall have the following meanings:
“Personal Information/Data” means personal information that can be associated with an identified or identifiable person. Personal information does not include information that does not identify a specific user.
“Process” means any method or way that we handle Personal Information or sets of Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Information.

2. SCOPE
This Privacy Notice applies to Personal Information that is Processed by us in the course of our business, when you use our products and services (“Products and Services”) and our website https://doingbetterltd.com/ (“Our Site”).
All individuals whose responsibilities include the Processing of Personal Information on our behalf are expected to protect Personal Information by adherence to this Privacy Notice.

3. WHAT PERSONAL INFORMATION WE COLLECT
The categories of Personal Information we collect depend on what Products or Services you are using, and the requirements of applicable law.

3.1. Information You Give Us Directly
Get in touch: When you contact us to start working with us, we collect your name and email address. We may require you to provide us with additional information as you use our Services or Products.
Payment and financial information. We may collect your payment and billing information.
Your Communications with Us. We collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services or Products, request customer support, or otherwise communicate with us.
Social Media Content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.

3.2. Other Information We Collect When You Use Our Services and Products
3.2.1. Device Information. We may collect certain information automatically when you use the Services or Products. This information may include your Internet protocol (IP) address, mobile and other hardware or device identifiers, browser information (including your browser type and the language you prefer), user settings, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services.
In addition, we may automatically collect data regarding your use of our Services and Products, such as the types of content you interact with and the frequency and duration of your activities.
3.2.2. Cookies, similar technologies (pixel tags/web beacons), Analytics Information, and Interest-Based Advertising technologies.
We and third parties that provide content, or other functionality on the Services or Products, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services or Products. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.
Cookies. Cookies are small text files stored on your Internet browser. You may opt out of certain types of tracking on the web, including certain analytics and tailored advertising by changing the cookie settings via our consent tools.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
3.2.3. Analytics.
We may use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services or Products. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

3.3. Information from Other Sources
3.3.1. We may receive information about you from other sources, including through third party services and organizations to supplement or verify information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with Products and Services.

4. HOW WE USE YOUR PERSONAL INFORMATION
We use your information for a variety of business purposes, including to:
4.1. Operate our business, fulfill our contract with you and provide you with our Services and Products, such as:
● Managing your information;
● Responding to your questions, comments, and other requests;
● Providing you with our Services and Products;
● Communicating with you about your activities on our Services and Products, and policy changes; and
● Answering your requests for customer or technical support.

4.2. Analyze and improve our Services and Products, such as:
● Verifying your identity and preventing fraud;
● Detecting bugs or other software issues;
● Preventing potentially prohibited or illegal activities;
● Ensuring internal quality control;
● Measuring interest and engagement in our Services and Products;
● Conducting research and development;
● Developing new products and services;
● Enforcing our Terms of Service; and
● To comply with our legal obligations, protect your vital interest, or as may be required for the public good.

4.3. Personalize our communications with you, including:
● Providing you with customized materials about offers, Services and Products that may be of interest, including new Products or Services; and

● Other purposes you consent to, are notified of, or are disclosed when you provide Personal Information.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as described below.
4.4. Use De-identified and Aggregated Information
We may use Personal Information and other data about you to create de-identified and aggregated information.
4.5. Automatic Collection Technologies
We, as well as third parties that provide content, or other functionality on the Services and Products, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services or Products.

5. HOW WE SHARE YOUR PERSONAL INFORMATION
We do not share your Personal Information with third parties for their own use without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights or to protect us or third parties.
We may share your Personal Information with the following categories of third parties:
Service Providers. We may share any Personal Information we collect about you with our third-party service providers. The categories of service providers (processors) include: IT and related services; information and services; payment processors; customer service providers; and vendors to support the provision of the Services and Products.
Business Partners. We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
Affiliates: We may share personal information with our affiliated companies.
Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
International Data Transfers. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, and you authorize us to transfer your Personal Information across national borders and to other countries. The privacy protections and rights of authorities to access your Personal Information in these countries may not be equivalent to those in your country. We have taken appropriate safeguards to require that your Personal Information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well.

6. YOUR CHOICES
6.1. General
Under the law of some jurisdictions, you may have certain choices about your Personal Information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below.
6.2. Email and Telephone Communications
You may choose to opt-out of receiving certain email communications by following the instructions in the email to unsubscribe. However, we will continue to send transaction-related emails regarding products or services you have requested.
We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
6.3. “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

7. HOW LONG DO WE STORE YOUR PERSONAL INFORMATION
We retain the Personal Information we receive as described in this Privacy Notice for as long as you use our Services or Products or as necessary to fulfill the purpose(s) for which it was collected, provide our Services or Products, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

8. SECURITY
We take reasonable steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Even so, no system is 100% secure. This means we cannot guarantee the security of your Personal Information and do not assume any responsibility for the unauthorized use or access to your Personal Information under our control.

9. CHILDREN’S INFORMATION
The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below. If we learn that we have collected any Personal Information in violation of applicable law, we will promptly take steps to delete such information.

10. YOUR PRIVACY RIGHTS
Under the law of some jurisdictions, you may seek confirmation regarding whether we Process Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete that information where it is inaccurate or has been Processed in violation of the applicable law.
EEA (European Economic Area) rights
If you are habitually located in the European Union, Switzerland, or United Kingdom, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. Before we process any request, we will take commercially reasonable steps to verify your identity.

11. COMPLIANCE AND ACCOUNTABILITY
If after reviewing this Privacy Notice, you would like to contact us about our privacy practices or exercise any of your privacy rights, you may use any of the methods set out in Section 12 of this Privacy Notice.
This Privacy Notice shall be implemented by us and all our operating divisions, subsidiaries and affiliates. We have put in place mechanisms to verify ongoing compliance with this Privacy Notice.

12. HOW TO CONTACT US
For questions about our Privacy Notice, to make choices about receiving marketing or promotional communications, or if you have a request to access, correct or delete your personal data, you may contact us by email: info@doingbetterltd.com or telephone: +35796718500.
If you are habitually located in the EEA, you also have a right to contact your local Data Protection Authority.

13. CHANGES TO OUR PRIVACY NOTICE
We may update this Privacy Notice from time to time in our sole discretion, so please review it frequently. We will notify you of material changes via a notice on this web site or as otherwise required by applicable law. Your continued relationship with us after the posting or notice of any amended Privacy Notice shall constitute your acknowledgement and agreement to be bound by any such changes. Any changes to this Privacy Notice take effect immediately after being posted or as otherwise provided by us.

Updated on 21.11.2022