Effective date: May 11, 2023

Limited Liability Company "Sigma Software DC" (“Sigma”, “we”, “our”, or “us”), take all necessary measures to ensure that personal data is being processed by us in a lawful, fair and transparent manner.

Sigma is the data controller in respect of the personal data you provide to us when you register for and/or use any of our services provided through Dovkolo Club application (the “Services”). This privacy notice describes what personal data Sigma may process, the purpose and legal basis for the processing, your rights in relation to Sigma, as well as how you can exercise those rights.

Sigma is committed to protecting your personal data and it is important to us to ensure that your personal data is being processed in a secure way. We are responsible for ensuring that the processing of personal data is carried out in accordance with applicable law and this privacy notice. We use appropriate technical and organizational measures with respect to the amount and sensitivity of personal data.

It is important that you read and understand this privacy notice before you use the Services. You should not use the Services if you do not approve of this privacy notice.

What personal data do we collect and where from?

If you register an account to use the Services, or if you contact Sigma through different communication channels, you may provide information to us that is considered personal data under applicable data protection laws.

Sigma may process the following personal data on you:

• e-mail
• name/nickname
• IP address
• geolocation
• phone number
• contact book
• Apple ID/Google ID
• Your reviews, comments, photos and other user-generated information that you actively choose to share within the Services.

We process data provided directly from you (e.g. when you fill in a registration form or account), other data we get on you (e.g. your IP address), data we may get from third parties if you authorize on the Services via third-party products (e.g. Google, Facebook, etc.).

Purpose and basis for processing

| Purpose of the processing | Legal basis for the processing | | --- | --- | | Setting-up, maintenance and managing your account | Performance of a contract | | Provision of the Service | Performance of a contract  | | Receiving and responding to your communications and requests | Necessary for the performance of a contract where such communication relates specifically to the Services, otherwise legitimate interests so that we can respond to your request | | Notifying about updates to the Services, including updates to this Privacy notice and terms of use applicable to the Services | Performance of a contract – when we notify you on updates to the Services;    Legitimate interest – when we notify you on some of our new Services and features or Services of our affiliates, as well as updates to this privacy notice or the terms of use applicable between you and us   | | Preparation of statistics relating to the Services | Legitimate interest – Sigma monitors the usage of the Services to be able to improve and enhance the Services and thereby provide our users with the best experience possible  | | Fixing bugs in the Services and ensuring the proper operation of the Services | Legitimate interest | | Ensuring the safety and security of the users of the Services and the safety and security of the provision of the Services | Legitimate interest | | Limiting access to the Services | Legitimate interest – in some cases, Sigma may make its Services available only to users in certain countries |

Retention of personal data