Updated: 29/08/2024
The provisions below highlight the policy of Virtual Technology Stack Inc (VTS Inc.) (collectively, “Dooyu,” “the Company,” “we,” “us,” “our”) regarding the collection, storage, use, processing, sharing, retention and deletion of data that Dooyu collect from Users (collectively, “you,” “your,” “fans,” “influencers”). For the purposes of this policy, data refers to the information located within the systems of Dooyu and Dooyu shall be the Data Controller and shall be responsible for the processing of User information. Users are therefore encouraged to read and understand this Privacy Policy before using Dooyu services and to contact Dooyu Data Officer using the contact information below in case of any issues relating to User privacy rights, complaints or infringements.
1 - Information We Collect
a) Dooyu require Users to provide some information such as name, gender, nationality, date of birth, email addresses and other personal information. Such information that reveals the identity of a user is called personal data and may include both identity data as well as contact information.
b) Users who login through Twitter authorize Dooyu to collect their login information, profiles, photos, videos, usernames, and passwords. Dooyu shall collect such personal information that is necessary to allow Users to access Our services and shall process and store them safely in accordance with the terms of this policy.
c) Dooyu equally collects billing and financial information of Users who subscribe to the services of Dooyu. Such data may entail billing addresses, email, telephone numbers, dooyu.com will not sell, purchase, provide, exchange or in any other manner disclose Account or Transaction data, or personal information of or about a Cardholder to anyone, except, it’s Acquirer, Visa/Mastercard Corporations or in response to valid government demands and government issued document numbers where necessary. This financial information may also be collected and stored by third-party service providers and will be subject to their privacy policies.
d) Dooyu will also collect information relating to transactions by Users such as payment and subscription details as well as details about the videos, posts or images that you purchase or subscribe.
e) Dooyu will collect technical data on User devices including the IP addresses, cookies settings, browser type, version and language, wireless access points and names, app crashes, plug-in types, location, time zone, operating systems and other vital information the We consider vital.
f) Users may also upload on the Dooyu platform such contents including images, videos and other posts and Dooyu shall collect such content information posted on its platform.
g) Dooyu shall similarly collect your profile information especially information about your preferences, username, feedback, password, and answers to surveys.
h) Dooyu collects information about traffic, products, services and complaints regarding your use of Our platform as well as User’s choice on marketing and communications from Dooyu.
i) Dooyu may at times collect Aggregated Data which shall be anonymized in most instances and comprises of statistical and demographics.
j) Dooyu does not intentionally collect personal information of minors and will not collect any special group of personal information that may expose Users to discrimination or unfair treatment. Dooyu will not collect information about race, sexual orientation, religion, creed, criminal history etc. unless Users voluntarily give it out in their profiles or posts.
2 - Data Collection & Use of Cookies
a) Dooyu will collect Users’ information directly by asking the User to key in their personal and non-personal information on Our platform or indirectly using available technology.
b) Dooyu will use Cookies, Log files, Web beacons, server logs, tags and pixels to collect information on viewer traffic and generate related data. Dooyu shall use Cookies for its legitimate purposes only including User authentication, retention of User settings and preferences, analysing traffic and trends, and assessing the effectiveness of advertisement campaigns.
c) Dooyu may use Bluetooth, GPS or Wi-Fi connections to collect Users’ location and time zone.
d) Dooyu may collect Users’ profile information from third-parties such as Twitter for Users who register and login using Twitter. Dooyu will also get User information from payment processors, and Google.
e) Users may provide Content to be published or displayed by Dooyu to the public and may be transmitted to third parties. Users understand that they post or display their content at their own risk and Dooyu does not guarantee that its security system is perfect or impenetrable. Dooyu is not responsible for the actions of other Users regarding how they use the content that is publicly displayed. Thus, Dooyu does not warrant that User content will not be accessed by unauthorized persons.
3 - Legal Basis for Data Collection & Processing
a) Dooyu collects and processes Users’ data as part of its compliance with legal provision and on the basis that Users consent to such collection and processing. By accepting Our Privacy Policy and the Terms of Dooyu, Users are deemed to have consented to the collection of their data.
b) Dooyu shall only collect and process Users’ data in a lawful manner and to the extent necessary to enable Dooyu fulfill its services to Users. As a result, Dooyu will not require more information than is ordinarily acceptable within the practice, EU Regulation 2016/679 of the European Parliament and of the Council, of April 27, 2016 (General Data Protection Regulation), California Consumer Privacy Act of 2018 (CCPA), California's "Shine the Light" law (Civil Code Section 1798.83), and Nevada Revised Statutes Chapter 603A for European and USA Users.
4 - How We Use User Information
a) Dooyu will use Users’ information while performing the Terms of User agreements with Us. These include providing the services to you such as registration and logging in, monitoring your interaction with our platform and investigating complaints arising from your use of Our platform.
b) Secondly, Dooyu will use your information to fulfill its legitimate interests or those of third parties and to fulfill your interests.
c) Lastly, Dooyu will use your information so as to comply with its legal obligations, respond to subpoenas, valid court orders among others.
5 - Purposes for Use of Personal Information
a) Dooyu will use your personal information to help you register, administer and to login into our platform, respond to any queries made to Our customer support department and communicate Our services to you.
b) Dooyu will also use your personal information to help Us manage your account, maintain a profile, track your preferences, display your profile on the App for other users, verify your age and identity as well make payments for subscription-based services.
c) Dooyu will use your information to communicate to Users about changes to its terms, User account, complaints against a User and to ask for ratings and reviews of Our services.
d) Dooyu will use User information to enable them to post or display content, interact on our website, share their posts on Twitter, and communicate with influencers or fans.
e) Dooyu will use the information We collect to protect Our business interests, ensure the security of Our website and conduct internal audits.
f) Dooyu shall equally use the information gathered to develop, display and track website/App content shared between users and shared on third party platforms, improve our services, marketing, and User experience.
g) Dooyu shall use the device and cookies information to authenticate your account and profile each time you login and to enhance your general experience with the services offered by Dooyu whenever you access our services using different devices or browsers.
h) Dooyu shall use the information it collects for legal purposes in protecting a right, preventing crime, detecting and fighting fraud, and/or other illegal conducts.
i) Dooyu shall also use Users’ information to exercise and enforce Our rights, securing compliance according to the governing laws, and help law enforcers.
6 - Sharing of Information
a) Dooyu shall only share your third parties to achieve the purposes of our business including to enable Users get our services through third parties, to aid law enforcers, and for other legitimate purposes incidental to the use of Our platform.
b) Users’ posts and profile will be available to other users on the platform and a User may choose to share their posts on a third-party platform such as Twitter. User profile information will automatically be shared by the third party whenever you share your posts from Our platform.
c) Dooyu will share your information with third parties that it enlists to help in providing our services to you including companies hosting and managing our data, advertising, analytics, customer care, payment processing, marketing, and security operations.
d) Dooyu shall never sell User information to third-parties or exploit it commercial gain unless permitted under law or where User consent has been obtained.
7 - Disclosure of Information
a) Dooyu shall not disclose User’s personal data where the User consents to such disclosures or where the law requires certain data to be disclosed. As such, Dooyu will disclose your information to law enforcement so as to comply with applicable laws and regulations, subpoena, search warrant or other lawful requests for information or in order to enforce our rights if you violate our Terms of Service.
b) Dooyu shall also disclose User information to protect its rights and interests especially when the disclosure is necessary to help lessen its liability and/or losses in an actual or threatened lawsuit, enforce this contract and any other agreements, protect other users and the business interests of Dooyu, and to investigate, prevent and/or take action for illegal activity, unauthorized conduct or suspected fraud.
8 - Cross-Border/ International Data Transfers
a) Dooyu is located in Las Vegas, Nevada within the United States. Our servers are located in the United States. Sharing of data shall be both within the United States and Europe. Dooyu endeavors to safeguard your privacy by applying standard contractual clauses with any third party that it enlists in the provision of its services.
b) Dooyu may process, store, and transfer personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be comprehensive as your own. Dooyu shall put in place suitable mechanisms to ensure that your personal data receives an adequate level of protection where it is processed whenever there are international transfer of Users information and in accordance with the national laws of that country.
c) Users who are located outside the European Economic Area (EEA) or the United Kingdom (UK) or the United States consent to the processing, storage and transfer of their data within the EEA, United Kingdom and the United States. Such User consent shall be implied whenever a User submits their personal information and engages in the services of Dooyu.
d) Users who reside within the European Economic Area (EEA) or the United Kingdom (UK) understand that their personal information will be processed outside of the EEA or UK, including, for example, in the United States, and their data shall be transferred outside the EEA or UK.
e) Dooyu shall ensure that it accords a similar degree of protection to personal data that is transferred outside the EEA by requiring the recipient third party to agree to contractual clauses.
9 - Data Control
a) Users’ content and personal information remains entirely in the control of each individual user and they may opt to change or modify them whenever they so wish. Dooyu will not be held responsible for inaccurate profile description or posts made by any User.
b) Users may change their device settings to restrict or allow the collection of certain information by Our platform, block/ allow push notifications and accept/ decline the display of certain information.
c) Users have the option of deleting their account and their personal information will automatically be erased after thirty days. Users’ information other than personal information will be deleted immediately and remain unavailable to other users after an account is deleted.
10 - User GDPR Rights
a) Users have the right to access, review and modify their personal data at any time, right of portability or variation as well as a right to request that a copy of the information collected by Dooyu be sent to the User.
b) Users have a right to withdraw their consent to the collection, processing, storage and transfer of their personal data.
c) Users have the right to request a report on how their personal information is used. Users may request these reports by emailing us or contacting customer support.
d) Users may request Dooyu to amend, modify or correct information regarding the user which is inaccurate or is no longer necessary for the services.
e) Users may also request Dooyu to delete their data or to stop processing certain data and Dooyu shall comply within a reasonable after receiving communication from the User.
f) Users have the right to Dooyu to restrict the processing of their personal data for any reason and Dooyu shall comply within reasonable time.
g) Users may equally request Dooyu to transfer/ transmission their personal data stored or held in any jurisdiction and which remains within the control of Dooyu to another data controller.
h) Dooyu may legitimately decline requests by Users where it reasonably believes that such a request is unlawful, or where the same infringes on trade secrets and/or intellectual property or privacy rights of other users.
i) Disclosure of chats with other users require the written consent of the other user before releasing such information.
11 - California Residents
a) Users from California enjoy all the rights under Clause 10 above and any other rights that are specifically provided for under the California Consumer Privacy Act.
b) Users may request Dooyu to disclose the categories of personal information that it shared with third parties over the past twelve (12) months for the purposes of direct marketing by the third parties as provided for by California's "Shine the Light" law (Civil Code Section 1798.83).
c) California residents may opt out from the disclosure of their personal data to any third party for direct marketing purposes. Users will still receive selected offers directly from Dooyu even after opting out in accordance with California law.
d) Dooyu shall facilitate any requested disclosures within a period of one month following the receipt of a request to disclose said information. Users are encouraged to be patient as there may be backlogs and technological challenges in processing their requests.
e) Please note that Dooyu does not share personal information of Users with third parties for the purposes of direct marketing by the third parties.
12 - Nevada Privacy Rights
a) In addition to the rights already highlighted in Clause 10 of this policy, Nevada residents may exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A by contacting Dooyu via email.
b) Dooyu does not sell User’s data to any person or entity thus the Nevada Revised Statutes Chapter 603A may not be triggered.
13 - Security of User Information
a) Dooyu undertakes to take reasonable care and to employ commercially reasonable practices to help secure your data. Dooyu shall take measures to avoid the inappropriate loss, misuse, access, disclosure, alteration or destruction of your personal information.
b) Dooyu makes no representation, warranty or promise to the effect that your data will always remain secure.
c) Dooyu shall adopt routine monitoring of its service and systems for possible vulnerabilities and attacks and update the systems as appropriate. Dooyu will periodically review its standard practices and procedures on data collection, storage and processing and update its security measures.
d) Dooyu may automatically suspend its services either partly or fully without prior notice where it believes, suspects or has detected a serious breach to the security of users and its data. Users are encouraged to immediately report to Dooyu any suspected breach of security of personal information or hacking.
14 - Data Retention Period
a) Dooyu will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. Additionally, Dooyu shall retain Users’ personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with a User.
b) Dooyu shall consider a number of factors in determining the retention period for the User information including the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal data and whether we can achieve those purposes through other means. Lastly, we will consider the applicable legal, regulatory, tax, accounting, or other requirements.
c) Dooyu shall apply a safety period of three months or longer where a law requires a longer period than three months. Dooyu will therefore retain your personal information and activity log if it is necessary for its legitimate interests, or to ensure safety and security of other Users.
d) Dooyu will ordinarily delete or anonymize User information after the safety period of three months unless:
1 - It is a legal requirement to keep the data for a longer period. Dooyu will keep your traffic data for up to one year in compliance with its legal obligations to retain such data;
2 - Dooyu will keep records of all User consent and acceptance of Our Terms, and Privacy Policy for a period of five years;
3 - Certain types of information that is subject to a claim or dispute shall be retained until the claim is exhaustively resolved;
4 - Dooyu shall keep basic information about certain customers for seven years after they stop being customers for tax purposes or to comply with applicable law, including 18 U.S.C. § 2257 (Recordkeeping for Visual Depictions of Actual and Simulated Sexually Explicit Conduct) or
5 - Information may be retained for longer periods where it is in the legitimate interest of Dooyu to do so to prevent fraud, ensure User safety and the security of our system.
15 - Changes to this Policy
a) Dooyu reserves the right to modify this Privacy Policy at any time, and from time to time in order to reflect changes to our practices or for other operational, legal or regulatory reasons. Changes and clarifications will take effect immediately upon their posting on Our platform unless stated otherwise.
b) Dooyu will notify Users of any material changes to the collection, use, sharing and retention of Users’ information.
CONTACT US
For any queries, clarifications or additional information about this Policy and the use of your information, please reach out to Dooyu through our ticket system at https://support.dooyu.com/en or post mail to:
Virtual Technology Stack Inc
6166 S. Sandhill Road Suite 122
Las Vegas NV 89120