Privacy Policy

Last modification 2024-10-01

In this privacy notice we, DHOLEBYTE, explain how we process personal data when you visit the DHOLEBYTE website (dholebyte.com) (hereinafter referred to as «Platform») and use our services. All personal data is processed in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the local laws of the applicable EU Member State and/or other laws. of data protection.

We will ask you to give us your consent (or not, it is up to you) for the use of cookies in accordance with the conditions of this notice when you enter our platform for the first time.

Our platform offers privacy settings, which give you the possibility to decide how we process your personal data. With your privacy settings you can decide whether you want to receive direct marketing communications.

In this notice you will find answers to the following questions:

1. how we use your data;
2. when we transmit your data to third parties;
3. how long we store your data;
4. what is our marketing policy;
5. what rights you have regarding personal data;
6. how we use cookies files;
7. other issues you should take into account.

In case of any question or if you wish to exercise any of your rights indicated in this notice, you can contact us through one of the methods presented in the section. Contact.

In case of any question related to privacy matters, you can contact us via email: contact@dholebyte.com.

If the Privacy Notice is translated into other languages and there are discrepancies between the English version and said translation, the English version prevails unless otherwise indicated.

General principles of data protection and confidentiality

DHOLEBYTE will process all personal data in accordance with the following data protection processing principles:

• in a legal, loyal and transparent manner with regard to the interested party (legality, loyalty and transparency);
• the data will be collected and processed only for specific, explicit and legitimate purposes and will not be subsequently processed in a way that is not compatible with these purposes (limitation of purpose);
• ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed (data minimization);
• ensure that personal data is accurate and current where necessary (accuracy);
• ensure that personal data are stored in a form that allows the identification of the interested parties for a period no longer than necessary for the purposes for which the personal data are processed (storage limitation) ;
• process personal data in a way that ensures its adequate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (integrity and confidentiality ).

Any and all information processed by DHOLEBYTE is considered strictly confidential. All information is stored securely and accessed only by qualified and authorized personnel.

1. How do we use your personal data?This section presents the following information:
   • categories of personal data we process;
   • in the case of personal data that we do not obtain directly from you, the source and specific categories of such data;
   • purposes for which we may process your personal data; and
   • the legal bases of your treatment.

So what personal data do we collect and why?

5. We process data about your use of our Platform and services(«Usage Data»). The data used may include your IP address, geographical location, internet browser type and version, operating system, referral source, duration of your visit, pages viewed and navigation paths on the platform, as well as information about time, the frequency and pattern of use of the service. We obtain this data through the use of cookies or similar technologies. We process this data to better understand how you use our Platform and its services. The legal basis for this processing is our legitimate interest, that is, monitoring and improving our Platform, tracking usage trends, carrying out commercial analysis and adapting the services to the individual interests of each user.
6. We process your account data (“account data”). Account data may include your name and email address, phone number and other information you provide when registering, as well as your purchase history. We obtain this data directly from you. We process account data to manage our Platform, provide our services, ensure the security of our Platform and services and communicate with you. The legal basis for this processing is the performance of the contract between you and us and/or taking the necessary steps, at your request, to enter into such contract, as well as our legitimate interest, namely monitoring and improving of our Platform and our services.
7. We process information relating to the provision of our services to you on our Platform (“transaction data“). Transaction data may include your contact details, bank account details and transaction details. The transaction data is processed to assist you in the process of delivering or purchasing goods and to provide you with services and to maintain appropriate information about such transactions. The legal basis for this processing is the execution of a contract between you and us and/or taking the necessary steps, at your request, to enter into such a contract and exercise our legitimate interests, namely the proper administration of our Platform and business.
8. We process information relating to money laundering prevention measures(“AML data”). PBC data may additionally contain domicile or residential address, identification document number including your photograph, documents related to the sources of your assets, utility bills and others. In some cases, we are required by law to request such information to fulfill “know your customer” obligations, and it is our legitimate interest to ensure that only trusted sellers can sell their products on the Platform.
9. We have implemented a fraud detection process to prevent any fraudulent transactions (“fraud detection data”). To ensure adequate risk and fraud detection, effective prevention of fraudulent transactions and to improve our fraud detection process, we collect and process various account data, transaction data, technical information of the browser and the device used, data of use that allow us to determine whether the user’s actions present suspicious behavior (for example, if the user is a bot, if they have already tried to defraud us, and other similar indications related to fraudulent behavior). Our internal system may generate additional information, such as unique identifiers or data collected about transactions, accounts, usage, etc. The legal basis for this processing is our legitimate interests, namely to reduce the number of fraudulent transactions and to comply with the requirements of payment service providers and card system operators.
10. We may process the information you provide to us for the purpose of subscribing to our emails and newsletters (“direct marketing data“). Direct marketing data is processed to send you relevant messages and newsletters. The legal basis for this processing is your consent: In addition, if we have already sold goods or provided services to you on our Platform and you do not object, we may also process messaging data on the basis of our legitimate interest, namely processing to maintain and improve customer relationships
11. We process information related to any communication you send us (“correspondence data“). The correspondence data may contain the content of the communication and metadata related to the communication. If you communicate through the Platform, the Platform will generate the metadata associated with the communications made with the use of the Platform’s contact forms. The correspondence data is processed for the purposes of communicating with you and record keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our Platform and business, ensuring consistent, high-quality inquiries and investigating disputes between you and our employees.
12. When using our DholeByte Chat tool, we process information about how you use the content of your chats (“chat data”). The chat data is processed in order to enable you to use the DholeByte Chat function, as well as to ensure the correct functioning of the automatic chat filters, used to detect language prohibited by the DholeByte Chat rules. The legal basis for this processing is your consent, since the DholeByte Chat function is completely optional and you can use the Platform in its full capacity without activating the DholeByte Chat function.
13. We may process any of your personal data identified in this notice where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in administrative or extrajudicial proceedings. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
14. We may process any of your personal data identified in this notice where necessary to obtain or maintain insurance coverage, manage risks or obtain professional advice. The legal basis for this processing is our legitimate interests, namely the adequate protection of our business against risks.
15. In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your personal data. vital interests or the vital interests of another natural person.

1. When do we transmit your data to third parties?

1. We may disclose your personal data to your contracting party (Seller, Sales User or Purchase User, respectively) as reasonably necessary for the performance of the contract between you and these third parties or to comply with legal obligations.
2. We may disclose your personal data to any member of our group of companies (including our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this notice. This may include internal administration purposes, as well as the provision/sharing of IT services or data centers in the group.
3. We may disclose your personal data to our insurers and/or professional advisers as reasonably necessary for obtaining or maintaining insurance coverage, managing risks, obtaining professional advice or the establishment, exercise or defense of legal claims, whether in judicial or administrative or extrajudicial proceedings.
4. We may disclose your personal data to our fraud prevention, risk and compliance service providers as reasonably necessary to protect your personal data and comply with our legal obligations.
5. We may disclose your personal data toour payment service providers. We will share transaction data with our payment service providers only as necessary to process your payments, transfer funds and handle complaints and queries related to such payments and transfers.
6. We may disclose your personal data to our courier service providers. We will share relevant delivery data (for example, recipient name, contact information and delivery address) only as necessary to deliver the purchased products and handle complaints and queries related to such deliveries. For more information, you can access the privacy policies or terms and conditions of the service providers. For example, if your shipment is processed using VSPV or UAB solutions, then your Policy Privacyapplies to the processing of your personal data. If your shipment is delivered by Mondial Relay, your General Terms and Conditionsapply to the processing of your personal data.
7. We may disclose your personal data to other service providers as reasonably necessary to provide specific services (including server and maintenance providers, email service providers, newsletter sending service providers , consumer review websites and other service providers). We take all necessary measures to ensure that such subcontractors apply appropriate organizational and technical measures to ensure the security and privacy of your personal data.
8. Other than the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.
9. Some service providers listed in this section may be based outside the Republic of Lithuania, the European Union and the European Economic Area (EEA). However, we always try to ensure that all your data is processed within the EEA. Please note that personal data may be less protected in non-EEA countries compared to EEA countries. We strictly monitor developments in case law and guidance from the Court of Justice of the European Union and data protection supervisory authorities on transfers outside the EEA, and carefully assess the conditions under which your data is transferred and the conditions under which they can be processed and stored after transfer to the aforementioned entities. To ensure the appropriate level of data security and guarantee the legality of data transfer, we subscribe to the Standard Contractual Clauses approved by the European Commission or ensure other bases and conditions established by legal acts. We will take all necessary measures to ensure that your privacy is properly ensured and protected. For more information about appropriate safeguards, you can contact us by email: contact@dholebyte.com.

1. How long do we store your data?

1. Your personal data that we process for any purpose or purposes will not be stored for longer than is necessary for that purpose or those purposes. In any case, they will not be stored for more than:

1. 1. 1. account data will be stored for a maximum of 5 (five) years after your last transaction on the account;
      2. transaction data will be stored for a maximum of 10 (ten) years after the last provision of services.
      3. PBC data will be stored for the time necessary to comply with legal requirements;
      4. fraud detection data will be stored for the same time as account data or longer if the User’s Account is susceptible to fraud; li>
      5. direct marketing data will be stored for as long as your Account remains active unless you withdraw your consent beforehand;
      6. the correspondence data will be stored for a maximum of 6 (six) months after the end of the communication in question;
      7. chat data will be stored for as long as your Account remains active unless you withdraw your consent beforehand.

2. In some cases, it is not possible for us to specify in advance the periods for which your personal data will be stored. That is, usage data will be stored for the time necessary for appropriate processing.
3. Without prejudice to the other provisions of this Section, we may store your personal data for a longer period of time than indicated, in cases where:

1. 1. 1. it is necessary for our legitimate business interests, such as detecting and preventing fraud and improving security. If DHOLEBYTE suspends your User Account for security and fraud prevention reasons, we may retain certain information from that User Account to prevent that User from opening a new User Account in the future;
      2. what has been said is necessary to comply with our legal obligations. DHOLEBYTE may store some of your information to comply with its tax, legal and audit obligations;
      3. what has been said is necessary to resolve legal conflicts;
      4. what has been said is necessary to comply with our agreements and/or pursue or protect our legitimate interests;
      5. Because we protect the Platform from accidental or malicious loss and destruction, residual copies of your personal information may not be deleted from our backup systems for a limited period of time.

1. Marketing messages

1. If you consent, we will send you marketing messages by email and/or leave a notification on an account to let you know what we do.
2. Likewise, if we have already provided services to you and you do not object, we will inform you about our other products that may interest you, including other information related to them.
3. You can opt out of receiving marketing messages at any time.
4. You can do this in the following ways:

1. 1. 1. by choosing the corresponding link in any of our marketing messages;
      2. by contacting us through the Contact section.

5. After you have taken any of the planned actions, we will update your profile to ensure that you do not receive future marketing messages from us.
6. Please note that as our business consists of a network of closely related services, it may take a few days for all systems to be updated, so you may continue to receive marketing messages while we continue to process your request .
7. Opting out of marketing messages will not prevent you from receiving messages directly related to the provision of services, updates to our conditions and policies or other important messages related to the operation of the Platform.

1. Your rights

1. In this Section we summarize the rights you have under data protection laws. Some of the rights are complex, so we only point out the main aspects of these rights. You should therefore read the relevant laws and guidance from regulatory authorities for a full explanation of such rights.
2. Your other main rights under data protection law are as follows:

1. 1. 1. the right of access to data;
      2. the right to rectification (please note that you can exercise most of this right by accessing your account here;
      3. the right to deletion of your personal data;
      4. the right to limit the processing of your personal data;
      5. the right to object to the processing of your personal data;
      6. the right to data portability;
      7. the right to complain to a supervisory authority; and
      8. the right to withdraw consent.

3. The right of access to data. You have the right to confirm whether or not we process your personal data and, if we do, to access the personal data, together with certain additional information. This additional information includes details about the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Provided that the rights and freedoms of others are not affected, we will provide you with a copy of your personal data. The first copy will be free, but additional copies may be subject to a reasonable fee.
4. The right to rectification.You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5. In some circumstances you have the right to have your personal data deleted. These circumstances include cases where (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to the consent-based processing and there is no other legal basis for processing the data; (iii) you object to the processing under certain applicable data protection legislation; (iv) the processing is carried out for direct marketing purposes; or (v) the personal data has been processed illegally. However, there are exclusions from the right of deletion. These exclusions include cases when the treatment is necessary: (i) for the exercise of the right to freedom of expression and information; (ii) for compliance with our legal obligation; or (iii) for the establishment, exercise or defense of legal claims.
6. In some cases you havethe right to limit the processing of your personal data.Such circumstances are the following: (i) you claim the accuracy of the personal data; (ii) the processing is unlawful but you object to the deletion; (iii) we no longer need the personal data for the purposes of our processing, but you need the personal data for the establishment, exercise or defense of legal claims; and (iv) you have objected to the processing, pending verification of such objection. In cases where processing has been restricted on this basis, we may continue to store your personal data, but we will only continue to process such data in another way: (i) with your consent; (ii) for the establishment, exercise or defense of legal claims; (iii) for the protection of the rights of another person; or (iv) for reasons of important public interest.
7. You have the right to object to the processing of your personal data by uson grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that it is necessary to: the fulfillment of a mission carried out in the public interest or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will stop processing the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.< /li>
8. You have the right to object to the processing of your personal data by us for direct marketing purposes (including performance analysis for direct marketing purposes). If you object to this, we will stop processing your personal data for this purpose.
9. You have the right to object to us processing your personal data for scientific or historical research purposes or for statistical purposes as it relates to your particular situation unless such processing is necessary for compliance. of a task carried out for reasons of public interest.
10. The right to data portability.To the extent that the legal basis for our processing of your data personal be:

1. 1. 1. consent; or
      2. the execution of a contract or the measures taken at your request before concluding a contract, necessary to conclude it,

11. If you consider that our processing of your personal information infringes data protection legislation, you have the right to lodge a complaint with a supervisory authority responsible for data protection. You can do so in the EU Member State of your habitual residence, your place of work or the place of the alleged infringement. Our data processing is subject to the supervision of the State Inspectorate for Data Protection of the Republic of Lithuania, with the office at: L. Sapiegos St. 17, LT-10312, vdai.lrv.lt
12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. The withdrawal of consent will not affect the legality of the processing prior to it.
13. In addition to the specific action provided in this Section or on the Platform, you may also exercise any of the rights indicated here by contacting us at Contactor through contact@dholebyte.com.

1. About cookiesWe use cookies on our Platform to personalize its operation to the extent possible, and they can contribute to ease of use when browsing our Platform.< strong>What is a cookie file?
   • A cookie is a small text file placed on your device, which enables the properties and functionalities of our Platform to function. For example, cookies allow us to identify your device and protect your access to the Platform. They allow the Platform to store such data as:
   • The login data (IP address of the login device, login time, location from which the login is attempted);
   • Browser type;
   • Demographic data (age group, gender);
   • Data about the way you use the Platform (what sections you visit, what products you are interested in).
2. The cookies we useWe use four main types of cookies for the following purposes:

1. Necessary cookies:These are cookies that are necessary for the page to function and cannot be deactivated in our systems. They are typically only set in response to actions taken by you that amount to a request for services, such as setting your privacy preferences, logging in, or filling out forms. You can set your browser to block or warn you about these cookies, but in this case some parts of the page will not work;
2. Analytical cookies:these cookies allow us to count visits and traffic sources, so that we can measure and improve the performance of our website. They help us know which pages are the most and least popular and see how visitors move around the website. All information collected by these cookies is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our website;
3. Preference Cookies: These cookies allow a website to remember information that changes the behavior or appearance of the page, for example your preferred region.
4. Marketing cookies:these cookies may be set through our website by our advertising partners. These companies may use them to create a profile of your interests and show you relevant advertisements on other websites. They do not store personal information directly, but are based on the unique identification of your browser and Internet device. If you do not allow these cookies, you will experience less personalized advertising.

1. Cookies used by our service providers

1. Our service providers use cookies (third-party cookies), and these cookies may be stored on your computer when you use our Platform.
2. The complete list and description of the cookies used can be consulted at com by clicking on Cookies Preferences in the footer.

1. How can you control cookies?

1. Most browsers allow you to reject and delete cookies. The methods for doing this vary from browser to browser and version to version. However, you can obtain up-to-date information on blocking and deleting cookies through the information provided on the support web pages of the respective browser, for example Chrome; Firefox; Internet Explorer ; Safari; Edge. To learn more about how to manage cookies, go to: https://www .allaboutcookies.org/manage-cookies/or https://www.youronlinechoices.com/.
2. Blocking all cookies will have a negative impact on the usability of many web pages.
3. If you block cookies, you will not be able to use all the functions of our Platform.
4. You can adjust your cookie preferences by clicking the Cookie Preferences link in the footer of the page.

1. Third-party advertisingThe Platform uses Google Adsense, an online advertising service provided by Google. Google Adsense uses cookies, which are saved on your computer and allow your use of the Platform to be analyzed. Google Adsense uses “web beacons” (small invisible graphics) to collect information. Web beacons allow actions such as visitor traffic to be recorded and collected on the Platform. The information produced by the cookie and/or web beacon about your use of this Platform (including your IP address) will be transferred to and stored on a Google server in the United States. Google will use this information to evaluate your use of the Platform in relation to the advertisements displayed on the Platform, to compile reports for the Platform operator on the activity of the Platform and advertisements, and to provide other services related to the use of the Platform. the Platform and the Internet. Google may also make this information available to third parties to the extent required by law or where the third parties concerned process this data on Google’s behalf. Under no circumstances will Google combine your IP address with other data it has.

If you do not wish to receive personalized advertising and/or wish to disable the collection and use of your data, you can disable Google’s use of cookies for such purposes by accessing Google’s ad settings at https://adssettings.google.com and adjusting the settings as necessary. Please note that if you delete all cookies from your device, Google may store new cookies for these purposes, so you may need to renew your deactivation settings. Alternatively, you can deactivate the use of third-party cookies by accessing the deactivation page of the Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp.

1. Third party websitesOn the Platform you can find links to and from associated websites, information sources and websites of related parties. Please note that third-party websites that you visit by clicking on the links have their own privacy policies and we take no responsibility in relation to such privacy policies. We recommend that you familiarize yourself with the privacy policies of these websites before providing any personal data to them.
2. Personal data of children

1. 1. 1. Our Platform and services are aimed at persons over 16 years of age or of another age according to the legislation of the respective country that allows them to assume responsibility for the obligations arising from contractual relationships and have full capacity to take legal action.

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2. If we have reason to believe that we have personal data of a person under the mentioned age in our databases without having the consent of the holder of parental rights, we will delete that personal data.

1. Updating your dataPlease let us know if the personal information we hold about you needs to be corrected or updated.
2. Changes to the noticeAny changes to this notice will be published on the Platform and, in the event of substantial changes, we may inform you of them by email.