Privacy Policy

Effective date: 08.09.2024

Welcome to Our community at Vrtcl OÜ!

Users are provided with a thorough explanation of the processing of Personal Data in this Privacy Policy (hereinafter “Policy”). Maintaining Your privacy is Our top priority. This Policy explains how We use and safeguard Your Personal Data. In order to make the most of Our Platform, please read Our regulations. Please carefully read this Policy before using the Platform.Anyone may read, print, download, and store this Policy at any time. The Policy is regularly updated and is always accessible on the Platform. You recognize and agree that You have read, fully accepted, and agree to be governed by this Policy by providing Personal Data and accessing and using the Platform. If You do not agree to the Terms of this Policy, kindly do not use the Platform.We must let You know that even though We make every attempt to safeguard Your Personal Data, We can't promise that it won't be exposed to risk.Regulation (EU) 2016/679, the General Data Protection Regulation(GDPR) and California Consumer Privacy Protection Act of 2018 (CCPA), guided the creation of this Policy. In all EU Member States, the Data Protection Regulation is a directly applicable legal framework.If You have any questions about how We handle Your Personal Data, please contact Us at the address listed below service@Doublee.io.

TABLE OF CONTENTS

1. Terms & Conditions
2. Controller info
3. Purposes of Processing and legal basis for Processing
4. Data Policy
5. Will Personal Data Be Shared with Third Parties?
6. Control for do-not-track features
7. Terms of Personal Data storage
8. Rights of User concerning collected Personal Data
9. Change Of Data Controller
10. Applicable law
11. Changes to this Privacy Policy
12. Warranty and the limitation of the liability
13. Continuation of Personal Data storage
14. Contact Us

1. Terms & Conditions

“Doublee” - refers to “VRTCL OÜ”, Tax number: 16281254, registered under the address: Estonia, Harjumaa, Tallinn Maakri 19/2, 10145, incorporated under the laws of Estonia (hereinafter also “Company”, “We”, “Us” or “Our”).

“Platform” — the website doubl.ee and all its content and links, which can be used by You (also occurs as “Website”).

“Personal Data” — any information on a named or identifiable natural person that is voluntarily submitted.

“Automatically-collected information” — information collected about a User in an automatic way within the Website, or by related to the Website Third Parties.

“Data Subject” — the individual who uses the Platform (including Advertiser) and who, unless otherwise specified, coincides with the Data Subject (hereinafter - “You”, “Yours”, “User”).
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“Advertiser” - a person who has contacted the Company to advertise a product or service on the Platform.

“Processing” — any operation or set of operations which is performed on Personal Data or 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.

“Third Party” — a legal person, public authority, agency, or body other than the Data Subject, Controller, Processor, and persons who, under the direct authority of the Controller or Processor, is authorized to process Personal Data, other services which are integrated into the Platform and individuals who can receive cruise list or other information from the Platform.
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“Service” — the services provided by the Company through the Platform include the opportunity for Users to record Doublee, listen to other users' Doubleees and advertising services.

“Data Controller” — Company that determines the purposes and means of the Processing of Personal Data (also occurs as - “Controller”).

“Data Processor” — means a natural or legal person, which processes Personal Data on behalf of the Controller, specified in this Privacy Policy (also referred to - “Processor”). Companies to which the Company transfers information based on the User's consent or a contract may be considered Processors for the purposes of this Privacy Policy.

2. Controller info

Name of the legal person: VRTCL OÜ
Tax number: 16281254
Origin and/or legal address: Estonia, Harjumaa, Tallinn Maakri 19/2, 10145

3. Purposes of Processing and legal basis for Processing

‍3.1. Purposes of Processing
To grant You access to the Services, to address Your concerns or questions, to communicate with You, and in other customary situations, We use Your Personal Data. All Personal Data is stored securely under California Consumer Privacy Act 2018, the EU General Data Protection Regulation (Regulation (EU) 2016/679).Typically, We gather and utilize Your Personal Data for the following reasons:

1. Offering of Services;
2. To reply to Your requests for information;
   We will use Your Personal Data to reply to Your email or leave a voicemail if you contact Us. If We receive Your request, We will get in touch with You within 30 (thirty) days, though We'll do our best to get back to you right away.
3. To contact the Advertiser to provide information about the advertising Services through the Platform;
4. To protect Our legal rights and prevent abuse;
   To safeguard the Website and other commercial interests; to stop or take action against illegal activity, suspected fraud, or policy breaches that could jeopardize the safety of anybody or a Third Party or their legal rights.
5. Comply with legal obligations;
   In response to subpoenas, court orders, or other legitimate demands from regulators and/or law enforcement, including disclosures of national security or law enforcement information, We may share Personal Data and/or Use Data.
6. Providing support;
   Provide you with notice of any modifications to Our Service and provide support via email or chat while also fixing errors.

3.2.Legal basis for Processing
We process Your Personal Data based on the following legal bases:

• with Your consent for any one or more of the following objectives (listed below);
• as necessary for Our legitimate interests in providing the Services, provided that those interests do not outweigh Your fundamental freedoms and rights in terms of data confidentiality;
• as necessary for Our legitimate interests in marketing to You;  Your explicit consent to the processing of Your Personal Data for a certain purpose has been obtained. Please get in touch with Us if You want to revoke Your consent to the processing of Personal Data.

Your explicit consent to the processing of Your Personal Data for a certain purpose has been obtained. Please get in touch with Us if You want to revoke Your consent to the processing of Personal Data.

4.Data Policy

What do We collect from a Doublee User?

Personal Data provided by Users

If You voluntarily give Us personal information,
We may collect and store it. Personal Data is any information that could be used to identify You or another User as a natural person. Because they can interact with Doublee after registering, Users can choose to create an account in the app, accept an email invitation from another User, or create an account using a Google or Apple Id  profile. We cordially advise You to read Google's Privacy Policy at: https://policies.google.com in this situation and Apple Privacy Policy https://www.apple.com/legal/privacy/en-ww/.
That's what We typically gather:

• Name and Surname (for Advertiser);
• Age
• Gender
• Email

Automatically-collected information

We automatically gather various details about You in addition to the Personal Data You give (including Personal Data). While Users are navigating the website, We directly gather Usage Data from them. Usage Data enables Us to maintain the Website's functionality and enhance the effectiveness of the Services. Usage Data is gathered by Us when Users browse or use Our website, and it consists of:

• browser type;
• browser version;
• the type of device You are using;
• pages of Our Website that You have visited;
• Your visit to the Website at what time and on what date;
• the time You spent on these pages of the Website;
• unique device identifiers;
• IP Address (can be collected as Personal Data as well);
• geolocation Data (can be collected as Personal Data as well);
• other diagnostic Data.

Notifications

The Doublee app can provide You the following push-notifications with Your permission in the “Notifications settings” section of Users personal profile:

• questions from other users;;
• surveys;
• feedback emails;
• reminder emails;
• news emails;
• support emails.

You can withdraw consent to sending push-notifications at any time in Your profile.

5. Will Personal Data Be Shared with Third Parties?

We only share information with Your consent, to comply with laws, to provide You with services, protect Your rights, or to fulfill business obligations.

We may process or share Your data that We hold based on the following legal basis:

• Consent: We may process Your Personal Data if You have given Us specific consent to use Your Personal Data  information for the purposes defined in this Policy.
• Legitimate Interests: We may process Your Personal Data when it is reasonably necessary to achieve Our legitimate business interests.
• Legal Obligations: We may disclose Your information where We are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose Your information where We believe it is necessary to investigate, prevent, or take action regarding potential violations of Our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which We are involved.

More specifically, We may need to process Your Data or share Your Personal Data in the following situations:

• at the request of law enforcement officials;
• in the case of a court order requiring Us to disclose Your Personal Data in court proceedings; ;
• and other demands for disclosure of Personal Data as required by law.

• Business Transfers. We may share or transfer Your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of Our business to another company.

6. Terms of Personal Data storage

We keep Your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep Your Personal Data for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require Us to keep Your Personal Data for longer than the period of time in which Users have an account with Us.

When We have no ongoing legitimate business need to process Your Personal Data, We will either delete or anonymize such information, or, if this is not possible (for example, because Your Personal Data has been stored in backup archives), then We will securely store Your Personal Data and isolate it from any further processing until deletion is possible.

We also reserve the right, with Your express permission, to save your Personal Data and any content you publish on Doublee indefinitely so that it can be passed on to your successors with the necessary protections.

7. Rights of User concerning collected Personal Data

The non-property rights of Users with respect to Personal Data are unassignable and unbreakable.

The User has the following rights:

1. The right not to be subject to a decision based solely on automated processing;
2. The right to data portability. You have the right to ask Us to transfer Your Personal Data that We are processing based on Your consent to another controller;
3. The right to object. You have the right to object to Our processing of Your Personal Data;
4. Access to Your Personal Data, as well as confirmation from the Company of the Processing of Your Personal Data and the status of their storage;
5. At any time, You can withdraw Your consent to the Processing of Your Personal Data;
6. If You believe that Your fundamental privacy and data protection rights outweigh Our legitimate interest in continuing the Processing, You may disengage Your consent and request that Your Personal Data be erased. We may keep an anonymous record of the User's activities (except for Personal Data). The Company deletes all information it has about the User within 30 (thirty) days of receiving Your request for deletion of information. Please contact Us at admin@doubl.ee if You have any questions.
7. Changing Your Personal Data If there is an error, it has lost its relevance, or Your Personal Data has been deleted as a result of the completion of the purpose for which Data has been collected.
8. Request for information about the User that the Company has on file. The Company may take up to 30 (thirty) days to process a request, but We always make every effort to respond as soon as it is practically possible.
9. Filing a complaint against the Controller's disclosure of Personal Data, if necessary for lawful purposes in court or at stages leading to potential legal actions arising from improper use of this Website.
10. Obtaining a copy of the User's Personal Data in a structured, machine-readable, and widely used format.

8. Change Of Data Controller

We have the authority to sell, transfer, or buy a new business. The objects exchanged in these kinds of transactions will probably include all of the User's information. In the course of a merger, acquisition, bankruptcy, reorganization, liquidation, or other similar transaction, We reserve the right to sell or otherwise transfer Personal Data. We will make every effort to maintain the degree of security that We currently offer.

9. Applicable law

Laws of Estonia shall govern this Policy.

All disagreements that can occur while using Our Website will be settled through official email talks between the User and the Controller.

The email that was provided during the registration process is the User's official email address.

All issues arising out of or related to this Privacy Policy shall be addressed in accordance with the law of Estonia, if they are not settled through settlement. The Court of Arbitration of the Estonian Chamber of Commerce and Industry (ACECCI) will finally decide any issues relating to or arising out of this privacy policy in accordance with its rules. The number of arbitrators shall be one. The seat or legal place of arbitration shall be London. The language to be used in the arbitral proceedings shall be English.

10. Changes to this Privacy Policy

We reserve the right to periodically review this Policy and make modifications in Our sole discretion. For the most recent updates, We advise reviewing Our Policy at least once a month. If We have Your email address, We will contact You through email if We make changes that significantly alter Your privacy rights.

If You disagree with the changes to this Policy, We advise You not to use the Website.

11. Warranty and the limitation of the liability

We take reasonable and acceptable steps to protect the Personal Data we collect via the Website in order to prevent unauthorized or unlawful access to, disclosure of, or deletion of Personal Data. Unfortunately, no data transfer or storage system can be guaranteed to be completely safe. As a result, even while We make every effort to protect Your Data, We cannot protect or guarantee the security of any information You send to Us.

Please be aware that We do not collect or process any of the Personal Data You send to other websites. On Our Website, We only gather, handle, and keep the Personal Data that You give Us voluntarily. You use the website and give Us Your information at Your own risk.

12. Contact Us

Please contact Us at admin@doubl.ee if You have any questions or concerns about Doublee’s Privacy Policy, or if You decide at any time that We no longer need to hold any of Your Personal Data.