What does this policy cover

Welcome to Dorja, the online and mobile service of Dorja Ltd (“Dorja,” “we,” or “us”). Our Privacy Policy explains how Dorja Ltd, and its affiliates collect, use, disclose, and protect information that applies to our visual communication platform (the “Service”), and your choices about the collection and use of your information. Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Use. If you do not want your information processed in accordance with this Privacy Policy in general or any part of it, you should not use our Service. This policy applies to all users of the Service.

Summary: Welcome, here is our policy on privacy. This policy sets out how Dorja Ltd collects and uses the information that we collect about you when you use the Service. This policy also explains the choices that you can make about the way that we use your information.

1. Information we collect

We collect the following types of information about you:

(a) Information you provide us directly

We may ask for certain information when you register for a Dorja service or correspond with us (such as a username, your first and last names, birthdate, phone number, profession and e-mail address).

We also collect any messages you send us through the Service (such as user feedback, search queries and prompts), and may collect information you provide in User Content you post to the Service (such as text and photos you send us). We use this information to operate, maintain, improve and provide the features and functionality of the Service to you, to correspond with you, and to address any issues you raise about the Service.

If you don’t provide your personal information to us, you may not be able to access or use our Service or your experience of using our Service may not be as enjoyable.

Summary: We collect info about you that you choose to give us, for example when you use the Service or otherwise interact with us.

(b) Information we receive from third-party applications

We may receive information about you from third parties. For example, if you access the Service through a third-party connection or log-in, such as Facebook Connect, by “following,” “liking,” adding the Dorja application, etc., that third party may pass certain information about your use of its service to Dorja Ltd. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook UID), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Service. You may also unlink your third-party account from the Service by adjusting your settings on the third-party service. If you unlink your third-party account, we will no longer receive information collected about you in connection with that service. And if you choose to integrate with a third-party application to enhance media, supercharge your workflow or share to social media, we could receive data from such apps (as well as disclose data to such apps). If you communicate with us via social media, including Instagram, Facebook or TikTok and choose to share your user generated content with us, we may receive information such as videos you’ve created, your photo, your account name and your comments about Dorja Ltd.

Summary: When you use our Service, for example, if you log in through a third-party application, we may obtain information about you from such third-party application.

(c) Information we receive from other third parties

We may obtain information about you from third-party sources, such as public sources, social media platforms (like Facebook, Instagram, LinkedIn and other platforms) and third-party data providers and information services. Examples of the information we may obtain from such third parties include your company, company size, job title and seniority, industry and other profile information. We may share your email address or other information to obtain and combine this information with information that you provide to us or other information that we collect when you use our Service. We do this to better understand your profile and interests so that we can deliver customized offers and other personalized services to you, such as to serve relevant offers to you via email, chatbots, phone or personalized advertising. You can opt out of Dorja collecting more data about you from third-party providers to tailor your experience and messages we send you.

Some of these providers may combine data collected from our Service through cookies, pixels, tags and similar technologies, with email or mailing addresses to which they have access to help us serve relevant offers to you.

We may also receive information about you and your engagement with our advertisements from our ad servers, ad networks and social media platforms. This may include the websites you visited before coming to Dorja so that we can determine advertising effectiveness and pay our referral partners.

If you prefer not to have your information used for this purpose, you can opt out at any time by emailing us at [email protected].

Summary: We may obtain information about you from third-party sources so that we can understand your interests and personalize our communications and promotions to you. You can opt out at any time.

(d) Information we collect from you automatically

We will directly collect or generate certain information about your use of the Service (such as user activity data, analytics event data, and clickstream data) for data analytics and machine learning, and to help us measure traffic and usage trends for the Service. We may also use third party analytics tools that automatically collect information sent by your browser or mobile device, including the pages you visit and other information, that assists us in improving the Service. For more information, please see the paragraphs below on cookies information, log file information, clear gifs, device identifiers, and location data.

Summary: We collect and generate certain info about how you use our Service automatically. This helps us to provide and improve the Service for you.

(e) Cookies information and information taken from similar technologies

When you visit the Service, we (and our third-party partners) may send cookies — small text files containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets Dorja do things like enhance your navigation through the site, remember your preferences and generally improve the user experience. Cookies also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service) and allow us or our business partners to track your usage of the Service over time. They also allow us to measure traffic and usage trends for the Service, deliver personalized advertisements that may be of interest to you and measure their effectiveness, and find potential new users of the Service.

You can control or reset your cookies and similar technologies through your web browser, which will allow you to customize your cookie preferences and to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

(f) Device identifiers

When you access the Service on a device (including smart-phones or tablets), we may access, collect and/or monitor one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers are small data files that uniquely identify your mobile device. A device identifier may convey information to us about how you use the Service. A device identifier may remain persistently on your device, to help you log in and navigate the Service better. Some features of the Service may not function properly if use of device identifiers is impaired. Device Identifiers used by Dorja Ltd include the Android Advertising ID and iOS Advertising Identifier.

Summary: Your phone or device sends us information about your usage.

(g) Location data

Dorja collects information to understand where its users are located for several reasons. It helps Dorja to localize and personalize content, comply with local laws, undertake aggregated analytics, understand if its users use Dorja for domestic, business or educational use, improve advertising efficiency and estimate the tax liability of Dorja.

Dorja Ltd may collect your precise or approximate location:

– from you, when you provide, correct or confirm your location (e.g., when you purchase products from us);

– by inferring your location from your IP address; and

– from our partners or your payment provider.

Summary: Dorja may collect and use your location data for personalization, analytics, advertising and tax purposes.

2. How we use your information

We use the information we collect about you for the purposes set out below:

• Providing you with the Service:We use information about you to provide the Service to you.
• For data analytics:We use information about you to help us improve the service and our users’ experience, including by monitoring aggregate metrics such as total number of visitors, traffic, and demographic patterns.
• For Service improvement (including analytics and machine learning): We may analyse your activity and customize the Service, and to train our algorithms, models and AI products and services using machine learning to develop, improve and provide our Service. You can manage the use of your data for training AI to improve our Service in the privacy settings page under your privacy settings.
• Customizing the Service for you: We use and combine the information you provide us and information about you that we collect automatically and receive from other sources (including information we receive on and off our Service) and combine it with information about the behaviour of other users to make sure that your use of the Service is customized to your needs.
• To communicate with you about the Service:We use your contact information to get in touch with you and to send communications about critical elements of the Service.
• To promote and drive engagement with the Dorja Ltd Service:We use your contact information to get in touch with you about taking part in our surveys or about features and offers relating to the Service that we think you would be interested in.
• Customer happiness: We use information about you, information that we collect, information that you provide to our customer happiness team, and information about your interactions with the Service to resolve technical issues you experience with the Service, and to ensure that we can repair and improve the Service for all users.
• For matters that you have specifically consented to:From time-to-time Dorja Ltd may seek your consent to use your information for a particular purpose. Where you consent to our doing so, we will use it for that purpose. Where you no longer want us to use your information for that purpose you may withdraw your consent to this use.
• For matters that we are required to use your information by law: Dorja Ltd will use or disclose your information where we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Dorja Ltd, our users or others.

Summary: Dorja uses information about you for different reasons, including to provide, customize and improve the Service.

3. Sharing your information

(a) How we share your information

We share your information with third-party service providers for the purpose of providing the Service to you, to facilitate Dorja’s legitimate interests or if you consent. These service providers are vetted by us and will only be provided with access to your information as is reasonably necessary for the purpose that Dorja has engaged the service provider. We require that such third parties comply with applicable laws, and have security, privacy and data retention policies consistent with our policies to the extent necessary for them to perform a business or technology support function for us.

Some of the third parties with whom Dorja may share your personal information are service providers who assist Dorja with functions such as:

• Billing;
• Customer support and customer management;
• Email services;
• Hosting and storage;
• Data analytics and predictive analytics;
• Data labelling and machine learning;
• Security;
• Advertising and marketing services;
• Domain name registration;
• Delivery of physical products; and
• Other service providers.

Summary: We might share some information about you with our business partners and third-party service providers to provide the Service to you or to fulfil Dorja’s legitimate business interests.

(b) How you can share your User Content

(i) Public Posts

Any information or content that you voluntarily disclose for posting to the Service, such as public User Content, becomes available to be read, collected and used by the public.

You may share your Dorja designs to your social media accounts, including LinkedIn, Facebook, Twitter, Pinterest and Tumblr. You should ensure that you familiarize yourself with the privacy policies of each of these services and any privacy settings that may apply to the designs you choose to share on those accounts.

(ii) Teams

If you are part of a Team, then any information or content that you create in that Team or activity you take within the Team may be shared with other Team members and the Team Owner. If requested by the Team Owner, Dorja may re-assign ownership of any User Content you post in the Team to the Team Owner or to another Team member. The Team Owner or any Team Administrator in your Team may also move, delete or edit any folders or items you share with them, or the Team. You should ensure that any personal information, confidential information, or User Content that you’d like to keep private is retained in a separate personal account.

(iii) Design Collaboration

If you accept an invite to view, edit, collaborate on or interact with a Dorja design then, subject to your privacy settings, we may share certain information about your interaction with that design with the design owner and other users who have access to that design, including the following:

While your name and avatar will remain visible to anyone that has access to a design, you can make your email and usage metrics anonymous by turning the ‘Share my design usage with collaborators’ toggle off in your privacy settings.

As the owner or editor of an individual design, you can choose to give other people access to your designs using the following link sharing settings:

(c) Sharing in connection with a merger, acquisition or reorganization

Dorja may also share, sell or transfer your information to third parties in connection with or contemplation of (including as part of the due diligence process) any merger, acquisition, reorganization, financing, sale of assets, bankruptcy or insolvency event involving Dorja or any portion of our assets, services or businesses. Information such as customer names and email addresses, User Content and other user information related to the Service may be among the items shared, sold or otherwise transferred in these types of transactions. You will be notified via email and/or a notice on the Service if such a transaction takes place.

Summary: If we sell our business, any of the info which we’ve acquired about you may be part of the sale.

(d) Sharing with other third parties

Dorja will also share your information with third parties in certain circumstances, such as where you consent to our sharing it with a third party for a particular purpose.

These third-party products and apps are not controlled by us, and this privacy policy does not cover how third-party apps use your information. You should review the terms and conditions of any third-party apps before connecting them to the Service. If you object to information about you being shared with these third parties, do not use the product or install the app.

Summary: We may share your data where you use third-party products or have integrated your use of Dorja with third-party applications that are not controlled by us.

(f) Sharing aggregate data

We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated such anonymized data with third parties

Summary: We may share anonymized data with third parties.

(g) Sharing with authorities

We access, preserve and share your information with regulators, law enforcement, police, intelligence sharing and take down services and others in accordance with our Authority Request Policy or where we have a good-faith belief that it is necessary to detect, prevent or address fraud, breaches of our Terms of Use harmful or illegal activity, to protect Dorja (our rights, property or intellectual property), you or others, including as part of investigations or regulatory enquiries or to prevent death or imminent bodily harm.

Summary: We may share data with authorities in accordance with our Authority Request Policy or where we feel it is necessary.

4. Advertising

We partner with third party ad servers, ad networks and social media platforms (like Facebook, Google) to deliver personalized advertisements (“ads”) on our Service and other sites that may be of interest to you and/or to measure their effectiveness, and/or to identify potential new users of our Service.

Dorja does not sell or rent the information we collect directly from you or about you from third parties with these third-party ad servers or ad networks for such parties’ own marketing purposes.

The Dorja Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information.

Summary: If we have ads on our site, we might use some of your info to show you appropriate ads. We may also use some of that info to send you relevant ads on other sites, like Facebook or Google.

5. How we transfer, store and protect your data

Your information collected through the Service will be stored and processed in the European Union, United Kingdom, Ghana and any other country in which Dorja or its subsidiaries, affiliates or service providers maintain facilities or employ staff or contractors.

Dorja’s U.S. subsidiary adheres to compliance with the EU-U.S. Data Privacy Framework, the Swiss-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Framework.

Summary: To run our Service, we’ll have to use our Dorja group members and vendors around the world. This means your information might be transferred to anywhere the Service is operated.

6. Keeping your information safe

Dorja cares about the security of your information and uses appropriate safeguards to preserve the integrity and security of all information collected through the Service.

Summary: We care about the safety of your data and have implemented industry recognized measures to protect it, but unfortunately, we can’t guarantee that nothing bad will ever happen to it.

7. Your choices about your information

(a) You control your account information and settings

We provide choices about how we process your account information:

• You can request access, correction or deletion of the data Dorja holds on you by contacting [email protected]; and

Summary: You have control over your data. If you have any questions about reviewing or modifying your account information, you can contact us directly.

(b) Rights in respect of your Information

The laws of some countries grant rights in respect of personal information. Individuals in certain countries, including the European Union, United Kingdom, and Brazil have the right to:

• Request access to their information;
• Request that we correct inaccuracies in their information;
• Request that their information be deleted or that we restrict access to it;
• Request a structured electronic version of their information; and
• Object to our use of their information.

In some circumstances Dorja will not be able to comply with your request regarding your personal data. If we are unable to remove any of your information, we will explain why. For example, we may not be able to provide a copy of your information where it infringes on the rights of another user. In some cases, you may have shared your information with third parties, such as by publishing a design on a third party’s website. In that case Dorja will not be able to delete the information, and you will need to contact that third party directly.

Summary: You may have specific rights in relation to your information depending on where you live.

8. How long we keep your information

Following termination or deactivation of your user account, Dorja will retain your profile information and User Content for a commercially reasonable time, and for as long as we have a valid purpose to do so. Dorja will retain your information for the purpose of complying with its legal and audit obligations, and for backup and archival purposes.

Summary: We retain your profile information and user content for the purpose of providing our Service to you and to comply with our legal and regulatory obligations.

9. Additional information for users in Europe

This section of the policy applies to Dorja users that are in the European Economic Area (EEA), Switzerland or United Kingdom (UK). Dorja processes your personal data in accordance with European laws and regulations, such as the General Data Protection Regulation (GDPR) and UK General Data Protection Regulation (UK GDPR).

(a) Controller’s details

For the purposes of the GDPR and UK GDPR, Dorja Ltd is the controller of your personal data.

In certain circumstances, we process personal data as a processor on behalf of our customer. Dorja’s Terms of Use set out the circumstances where Dorja processes personal data as a processor. In these cases, it is the Dorja customer that is responsible for the processing of your personal data. If you have questions or concerns about how your personal data is handled by one of our customers, you should contact the relevant customer that is using our Service and refer to their separate privacy policies.

(b) Legal bases for processing

If you are in the EEA, Switzerland or UK, we need a lawful basis to collect, use and disclose your personal data as a controller. Our lawful basis will depend on the information concerned and the context in which it is processed.

Generally, Dorja will collect and use your information as follows:

• Contractual necessity: We need it to provide the Service to you and fulfil our obligations to you under our Terms of UseFor example, resolving issues you may experience with the Service, obtaining payment for our Services and providing you with access to your designs.
• Legitimate interests: It is necessary for our legitimate interests for example, providing a useful and customized Service, sending you relevant marketing messages, displaying advertising and tracking its effectiveness, using information we collect about you (like your spending, platform usage, occupation and employer) so that we can make more informed predictions, decisions and offers for our users and enhancing our Service via research and development, data analytics, data labelling, machine learning and predictive analytics relating to your usage data. We do not rely on this lawful basis where our legitimate interests are overridden by your rights and interests.
• Consent: You consent to us, and our third-party partners, using your information in a certain way – for example, to hear about new features or offers, and for machine learning and predictive analysis relating to your User Content.
• Legal obligations: It is necessary for compliance with our legal obligations – for example, to disclose your information in response to law enforcement requests and to retain your information for our record keeping purposes.

Where we use your information for our legitimate interest, you have the right to object to that use. However, if you do, it may diminish the quality of the Service you receive or prevent you from using the Service.

Summary: If you are accessing our Service from Europe, Dorja Ltd is the controller of your personal data. In some cases, though, we may only be processing your information on behalf of a Team as a processor. We only process your data if we have a lawful basis. We may transfer your information outside of Europe subject to appropriate safeguards.

10. Changes to this Policy

We may update this policy from time to time to reflect our current practice and ensure compliance with applicable laws. When we post changes to this policy, we will revise the “Last Updated” date at the top of this policy. If we make any material changes to the way we collect, use, store and/or share your personal information, we will notify you on our website. We recommend that you check this page from time to time to inform yourself of any changes.

Summary: We won’t make any major changes to our Privacy Policy without giving notice – but it’s still a good idea to visit this page every now and then.

11. How to contact us

If you have any questions about this Privacy Policy or the Service, or wish to make a complaint please contact us at:

Email: [email protected]

The EDPO and EDPO UK can both be contacted at [email protected]. If you are in the EEA, data subject request forms can be accessed at http://edpo.com/gdpr-data-request/. If you are in the UK, data subject request forms can be accessed at https://edpo.com/uk-gdpr-data-request/.