Privacy Policy
DAYVIDENDE GROUP INC, with the registered seat at Ricardo Arias Street, Banking Area, Advanced Tower, 1st Floor, Panama City, Panama (the “Company”, “Dayvidende”) is the owner of Dayvidende website: www.dayvidende.finance and any associated subdomains, including Dayvidende application: dayvidende.finance/dapp (collectively: the “Websites”).
Dayvidende collects some Personal Data from the Websites and its Users and therefore is responsible for the use and protection of this data.
For what purposes Dayvidende collects personal data
Dayvidende will use personal, confidential and/or sensitive data of Users for one or more of the following primary purposes:
a. Provide the Services required by Users;
b. Comply with due diligence and the Know Your Customer (“KYC”) policies. Dayvidende may use the information collected, as needed or requested by regulators, government entities, and law enforcement to comply with applicable laws and regulations;
c. Provide customer support: Dayvidende may use the information to provide customer support and answer inquiries about the Services;
d. Safety and security: Dayvidende may use data to protect against, investigate, and stop fraudulent, unauthorised, or illegal activity. Dayvidende may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect Users and the Company.
Types of data collected
Dayividende will only request personal data that is strictly necessary for the provision of the Services, respecting the principle of proportionality which states that “only data that is adequate, relevant and limited to the minimum necessary in relation to the purpose for which it is required shall be requested”.
2.1. Publicly available blockchain data
When a User connects a blockchain wallet to the Websites, Dayvidende collects and logs his/her publicly-available blockchain address to learn more about his/her use of the Websites and to screen the wallet for any prior illicit activity. Blockchain addresses are publicly available data that are not created or assigned by Dayvidende or any central party and by themselves are not personally identifying. Dayvidende is not responsible for the use of any of the blockchains and data processed in the DeFi space.
2.2. Information from Local Storage and other tracking technologies
Dayvidende and its third-party services providers may access and collect information from Local Storage, mobile device ID, cookies, web beacons, and other similar technologies to provide and personalise the Services and features of the Services across sessions. For example, Dayvidende may use this information to remember the tokens Users import. Dayvidende may also use this information to learn about Users’ preferences, use of the Services, and interactions. Information Dayvidende collects from these technologies may include things such as browser type, referring/exit pages, operating system, device or browser language, and other device information. Dayvidende groups and analyses these User journeys collectively, in the aggregate, to improve the User’s experience.
2.3. Know Your Customer data
For the Users that require the registration process a third-party payment processor will collect their “KYC” documents.
These data will be of a personal and/or confidential nature, and may be:
Identification data: full name, gender, place and date of birth, age, personal identity card or passport, e-mail, country of residence, nationality(ies).
Contact details: landline and/or cell phone numbers, e-mail, physical address, mailing address, post office box.
Confidential data: politically exposed person, source of income, bank and commercial references, legal entity’s details.
The personal, confidential and/or sensitive data will only be shared when the User has requested services from Dayvidende and has given his/her consent for the transfer of the corresponding information.
2.4. Correspondence
Dayvidende will receive any communications and information provided directly via customer support, social media, or other official channels. Dayvidende will record the delivery information or identity documents that Users directly provide (for example name, email, zip code, country, city, residential address, phone number or ID documents, company’s name and details), the responses and interactions with the Services and the Websites.
2.5. Information from other sources
Dayvidende may receive information about a wallet address, or transactions made through the Websites from service providers to comply with legal obligations and prevent using the Websites in connection with fraudulent or other illicit activities.
Dayvidende will never ask to share private keys or seed phrases of wallets. This information is confidential.
Legal basis of processing
Dayvidende may process Personal Data relating to Users if one of the following applies:
a. Users have given their consent for one or more specific purposes. Note: Under some legislations Dayvidende may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law (Users under the GDPR Law);
b. Provision of Data is necessary for the provision of Services to the User and/or for any pre-contractual obligations thereof;
c. Processing is necessary for compliance with a legal obligation to which Dayvidende is subject; Dayvidende may share data during litigation, regulatory proceedings, compliance measures, and when compelled by subpoena, court order, or other legal procedure. Dayvidende may also share data when it is necessary to prevent harm to our users, our Company, or others and to enforce our agreements and policies;
c. Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Dayvidende. Dayvidende may share data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity. Dayvidende may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect our users and project;
d. Processing is necessary for the purposes of the legitimate interests pursued by Dayvidende or by a third party. Dayvidende may share information with service providers and vendors to assist in providing, delivering, and improving the Services.
Dayvidende does not share information with any third parties for marketing purposes.
e. Business changes. Dayvidende may transfer or share data with another entity in case of a merger, acquisition, bankruptcy, dissolution, reorganization, asset or stock sale, or other business transaction.
In any case, Dayvidende will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement. Any questions about this Policy, collection, use, or sharing of data can be asked through the e-mali: compliance@dayvidende.finance
Place
The Data is processed at Dayvidende's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Personal Data collected for purposes related to the performance of Services or a contract shall be retained until such Services or contract have been fully performed.
Personal Data collected for the purposes of Dayvidende’s legitimate interests shall be retained as long as needed to fulfill such purposes. Dayvidende may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Dayvidende may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Personal data protection
Dayvidende recognizes the responsibility regarding the processing and protection of information. The established security measures to adequately safeguard information are:
a. SSL encryption;
b. Server level firewall.
c. Security protocols to prevent unauthorized access to information systems;
d. Access control to systems and work equipment;
e. Authentication via user-controlled cryptographic wallets;
f. Data encrypted at-rest and in-transit.
Dayvidende cannot guarantee the complete security of communications through the information systems but can guarantee that all appropriate measures are taken and every effort to protect data is made. Dayvidende ensures complete confidentiality of the personal and/or confidential information.
Ultimately, Users are solely responsible for maintaining the secrecy of their usernames, passwords and private data. Users shall be careful whenever using the Websites.
Third-Party Cookies
Dayvidende uses services provided by Google and other third parties that use tracking technology, such as cookies, and Local Storage, to collect information about the use of the Services and interactions. Users can opt out of having their online activity and device data collected through these third-party services, including blocking cookies in browsers, blocking or limiting the use of an advertising ID, using privacy plug-ins or browsers, using opt-out tools on each device or browser.
The rights of Users
Users may exercise certain rights regarding their Data processed by Dayvidende. At any time, they may exercise these rights, which cannot be waived, except for the exceptions established in special laws. These rights will not be absolute, since they may not be exercised if there is any judicial or administrative process against the data subject.
In particular, Users have the right to do the following:
a. Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. Nevertheless, Dayvidende cannot edit or delete information stored on a particular blockchain. Information such as transaction data, blockchain wallet address, and assets held by an address that may be related to the data beyond our control. Because blockchain is a decentralised and/or third-party network, Dayvidende cannot delete, change or modify Personal Data from such networks.
b. Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
c. Access their Data. Users have the right to learn if Data is being processed by Dayvidende, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
d. Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
e. Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, Dayvidende will not process their Data for any purpose other than storing it.
f. Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from Dayvidende.
g. Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
h. Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object the processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Dayvidende or for the purposes of the legitimate interests pursued by Dayvidende, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users under the GDPR Law must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification.
9.1. How to exercise the rights to object
Any requests to exercise Users’ rights can be directed to Dayvidende through the e-mali: compliance@dayvidende.finance. These requests can be exercised free of charge and will be addressed by Dayvidende as early as possible and always within one month.
Legitimation for data processing
The basis of legitimacy for the processing of personal data carried out by Dayvidende lies in the Personal Data Protection Law 81 (March 26, 2019) of the Republic of Panama and in the express consent to the processing, storage and / or transfer of such data.
This privacy statement has been prepared based on provisions of the Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”) as well. According to GDPR, Dayvidende is a Data Controller and can act as a Data Processor as well.
This privacy policy relates solely to the Websites of Dayvidende, if not stated otherwise within this document.
Changes to the privacy policy
Dayvidende may modify the privacy and data protection policies at any time, due to updates and/or legal requirements, when deemed appropriate.
In the event that significant changes are made that affect privacy, notifications will be made through various means of contact, such as emails, a banner on our website, a pop-up or by means of a push notification (for example, through a banner, a pop-up or a push notification), so that the data subject can review and analyze the changes made. It will always be advisable to occasionally review the policies, as minor changes may have been made to the policy.
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