Doshi App Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. Please also use the Glossary at the end of this privacy notice to understand the meaning of some of the terms used in this privacy notice.

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1 IMPORTANT INFORMATION AND WHO WE ARE

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‍1.1 Purpose of this privacy notice

1.1.1 This privacy notice provides information about how Doshi App Limited collects, processes, stores, and shares your personal data when you use our Doshi app. The data collected is integral to providing you with an enhanced learning and earning experience while using our services.

1.1.2 You should read this privacy notice along with any other privacy or fair processing notices we might provide on specific occasions. These notices serve to give you complete awareness of our data usage and supplement each other rather than override.

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1.2 Controller

1.2.1 Doshi App Limited, a private limited company registered in England and Wales (company number 13807674), with a registered address at 36 Gloucester Place Mews, London W1U 8BA, is the controller responsible for your personal data (collectively referred to as “we”, “us” and “our” in this privacy notice).

1.2.2 If you have any queries about this privacy notice or want to exercise your legal rights, please reach out to us via email at: hello@doshi.app.

1.2.3 While you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection authority (www.ico.org.uk), we would appreciate the opportunity to address your concerns directly in the first instance.

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1.3 Tell us about changes to your data

1.3.1 To ensure that we provide the best possible service, it's vital that the personal data we have about you is accurate and up-to-date. Please inform us if your personal data changes during your association with us.

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1.4 Third-party links

1.4.1 The Doshi app may contain links to third-party apps or websites. Clicking these links or enabling those connections may allow third parties to gather or share your data. We don't have control over these third-party apps or websites and are not responsible for their privacy statements. We strongly advise reading the privacy notice of every third-party app or website you visit after leaving our app.

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2 THE DATA WE COLLECT ABOUT YOU

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2.1 Personal data, or personal information, refers to any information from which an individual can be identified. It does not include data where the identity has been removed (anonymous data).

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2.2 We may collect, use, store, and transfer different types of personal data about you, which we have grouped as follows:

2.2.1 Identity Data includes first name, last name, username or similar identifier, title, date of birth, and age.

2.2.2 Contact Data includes your email address.

2.2.3 Financial Preference Data includes information about your financial interests, preferences and habits.

2.2.4 Technical Data includes the type of mobile device you use, unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, or your device’s time zone setting.

2.2.5 Transaction Data includes details about your Dosh earning transactions, missions, referrals, competitions, and reward redemptions within our app.

2.2.6 Profile Data includes past engagement with our services, your interests, preferences, feedback, survey responses, and progress within our Learning Academy.

2.2.7 Usage Data includes information about how you use our app and services.

2.2.8 Marketing and Communications Data includes your preferences in receiving in-app notifications, newsletters, and marketing communications from us and our third parties, and your communication preferences.

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2.3 We may also collect, use, and share Aggregated Data (such as statistical data) for any purpose.

‍‍Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature in our app. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

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2.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offences.

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2.5 If you fail to provide personal data

2.5.1 There may be instances where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested. In such cases, we may not be able to provide the services outlined in the contract we have or are attempting to enter into with you (for example, to provide you with our services). If this is the case, we will inform you at that time.

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3 HOW IS YOUR PERSONAL DATA COLLECTED?

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3.1 We use various methods to collect data from and about you, including:

3.1.1 Direct interactions with you. You may provide us with your Identity, Contact, Financial Preference, Profile, Transaction, Marketing and Communications Data by contacting us through email, filling in forms in our app, or otherwise. This includes personal data you provide when you:

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3.1.1.1 Register to use our services;

3.1.1.2 Share your contact details through a referral link provided by one of our existing users;

3.1.1.3 Provide information to enable us to offer you our services or fulfil our contractual obligations;

3.1.1.4 Subscribe to publications or information in our app;

3.1.1.5 Request marketing materials to be sent to you;

3.1.1.6 Respond to surveys we conduct; or

3.1.1.7 Provide feedback to us.

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3.1.2 Automated technologies. As you interact with our app, we may automatically collect Technical and Usage Data about your device, actions, and usage patterns. This data is collected through the use of cookies, server logs, and other similar technologies.

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3.1.3 Third parties or publicly available sources. We may receive personal data about you from third parties and public sources. This can include:

3.1.3.1 Technical Data from parties such as analytics providers like Google;

3.1.3.2 Contact and Transaction Data from providers of technical, payment and delivery services;

3.1.3.3 Identity and Contact Data from data brokers or aggregators;

3.1.3.4 Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.

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4 HOW WE USE YOUR PERSONAL DATA

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4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

4.1.1 Where we need to perform the contract we are about to enter into or have entered into with you.

4.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4.1.3 Where we need to comply with a legal or regulatory obligation.

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4.2 Purposes for which we will use your personal data

4.2.1 We have set out below a description of all the ways we plan to use your personal data, and the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

4.2.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us via the means set out in paragraph 1.2.2 above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the text below.    

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‍Purpose/Activity: To register you as a new user.

‍Type of data: (a) Identity Data (b) Contact Data.

Lawful basis for processing (including basis of legitimate interest): (a) Performance of a contract with you.

‍‍Purpose/Activity: To provide you with our services, including providing you with in-app notifications.

‍Type of data: (a) Identity Data (b) Contact Data (c) Transaction Data.

Lawful basis for processing (including basis of legitimate interest): (a) Performance of a contract with you (b) Necessary for our legitimate interests (in order to provide you with our services) .

‍‍Purpose/Activity: To manage our relationship with you including: (a) notifying you about proposed changes to this privacy notice or our other terms and conditions; and (b) any changes to our app.

‍Type of data: (a) Identity Data (b) Contact Data (c) Marketing and Communications Data (d) Profile Data.

Lawful basis for processing (including basis of legitimate interest): (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (to inform you of any changes to our terms and conditions) (c) Necessary for our legitimate interests (to keep our records updated, to understand how our users use our services and to develop our services and grow our business).

‍‍Purpose/Activity: To provide you with rewards and prizes arising from your use of our services or after you have successfully referred our services to a friend via our referral program.  

‍Type of data: (a) Identity Data (b) Contact Data (c) Marketing and Communications Data (d) Profile Data (e) Technical Data.

Lawful basis for processing (including basis of legitimate interest): a) Performance of a contract with you (c) Necessary for our legitimate interests (to understand how our users use our services and to develop our services and grow our business).

‍‍Purpose/Activity: To run and protect our business, including our app  (including finding and resolving problem, analysing data, testing, system maintenance, support, reporting and hosting of data)  

‍Type of data: (a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data

Lawful basis for processing (including basis of legitimate interest): (a) Necessary for our legitimate interests (for running our business, providing IT services, network security, to prevent fraud and where we are reorganising how our business is structured) (b) Necessary to comply with a legal obligation.

‍‍Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you(including those of third parties).

‍Type of data: (a) Identity Data (b) Contact Data(c) Technical Data (d) Usage Data (e) Profile Data (f) Financial  Data (g) Marketing and Communications Data.

‍Lawful basis for processing (including basis of legitimate interest): (a) Necessary for our legitimate interests (to develop our services and grow our business) (b) You have provided your explicit consent.

4.3 Marketing

4.3.1 We aim to give you options about the personal data usage, especially in regards to marketing and advertising.

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4.4 Promotions from us

4.4.1 We may use your Identity Data, Contact Data, Technical Data, Usage Data, and Profile Data to understand what products or services might be suitable or interesting for you. This is how we determine which products, services, and offers might be relevant for you, which we call marketing.

4.4.2 You will receive marketing communications from us if you have requested information about a service we offer, or if you have registered for one of our services and have not opted out of marketing.

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4.5 Marketing from third parties

4.5.1 We will seek your explicit consent before we share your personal data with any other company for marketing purposes.

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4.6 Opting out of marketing messages

4.6.1 You can request us or third parties to stop sending you marketing messages at any time by following the 'opt-out' links on any marketing message sent to you or by contacting us via the methods specified in paragraph 1.2.2.

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4.7 Change of purpose

4.7.1 We will only use your personal data for the purposes for which we collected it, unless we consider that we need to use it for another purpose that is compatible with the original intent. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us via the means setout in paragraph 1.2.2.

4.7.2 If we need to use your personal data for an unrelated purpose, we will inform you and explain the legal basis that allows us to do so.

4.7.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, if it is required or permitted by law.

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5 PROVIDING YOUR PERSONAL DATA TO OTHERS

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5.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.2.2 above.

5.1.1 Internal Third Parties’ as set out in the glossary to this privacy notice.

5.1.2 ‘External Third Parties’ as set out in the glossary to this privacy notice.

5.1.3 If we choose to sell, transfer, or merge parts of our business or our assets, the new owners of our business or those assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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5.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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6 INTERNATIONAL TRANSFERS

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6.1 Whenever we transfer your personal data outside the UK, we make sure that it is protected in the same as in the UK by using at least one of the following safeguards:

6.1.1 Transferring your personal data to a country that is considered by UK data protection laws to provide an adequate level of protection for personal data.

6.1.2 Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

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7 DATA SECURITY

7.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to access it. They will only process your personal data on our instructions and they must keep it secret.

7.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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8 DATA RETENTION

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8.1 How long will we use your personal data?

8.1.1 We will retain your personal data only for as long as it is necessary to fulfill the purposes we collect edit for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

8.1.2 When determining the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means, and the relevant legal requirements.

8.1.3 For details on retention periods for different aspects of your personal data, you can contact us through the means outlined in paragraph 1.2.2.

8.1.4 Under some circumstances, you can request us to delete your data. For more information on this, refer to the 'Request erasure' section below.

8.1.5 There may be circumstances where we may anonymize your personal data (making it no longer identifiable as yours) for research or statistical purposes. In these cases, we may use this information indefinitely without further notice to you.

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9 YOUR LEGAL RIGHTS

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9.1 You have certain rights under data protection laws in relation to your personal data, as outlined below

9.1.1 You can request access to your personal data, a right also known as a "data subject access request." This allows you to obtain a copy of the personal data we hold about you and check if we are lawfully processing it.

9.1.2 You can request the correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. We may need to verify the accuracy of the new data you provide to us.

9.1.3 You can request the erasure of your personal data. This allows you to ask us to delete or remove personal data when there is no valid reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data if you have successfully objected to its processing (see below), if we have processed your information unlawfully, or if we are required to erase your personal data to comply with the law. However, we may not always be able to comply with your request for erasure due to specific legal reasons which we will notify you of, if applicable, at the time of your request.

9.1.4 You can object to the processing of your personal data if we are relying on a legitimate interest (or that of a third party) and you have a particular reason for objecting to this processing because you believe it impacts your rights. You also have the right to object if we are processing your personal data for the purpose of providing you with details of products, services, and offers that may be relevant to you. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.

9.1.5 You can request a restriction on the processing of your personal data. This allows you to ask us to suspend the processing of your personal data in the following scenarios:

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9.1.5.1 If you want us to establish the data's accuracy.

9.1.5.2 If our use of the data is unlawful but you do not want us to erase it.

9.1.5.3 If you need us to hold the data because you need it to establish, exercise, or defend legal claims, even if we no longer require it.

9.1.5.4 If you have objected to our use of your data, but we need to verify if we have legitimate grounds to continue using it.

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9.1.6 You can request the transfer of your personal data to you or a third party. We will provide your personal data to you or a third party you have chosen, in a commonly used format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.

9.1.7 You can withdraw consent at any time if we are relying on consent to process your personal data. However, this will not affect the legality of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will inform you if this is the case at the time you withdraw your consent.

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9.2 If you wish to exercise any of the rights set out above, please contact us through the means outlined in paragraph 1.2.2.

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9.3 No fee usually required

9.3.1 You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request under these circumstances.

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9.4 What we may need from you

9.4.1 We may need to request specific information from you to confirm your identity and ensure your right to access your personal data or exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to anyone who has no right to receive it. We may also contact you to ask for further information to speed up our response.

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9.5 Time limit to respond

9.5.1 We aim to respond to all legitimate requests within one month. Occasionally, if your request is especially complex or you have made several requests, it may take us longer than a month. In such a case, we will notify you and keep you updated.

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10 GLOSSARY

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10.1 Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

‍10.2 Internal Third Parties refers to other companies in our corporate group who may need to provide you with services.

‍10.3 External Third Parties refers to:

10.3.1 Service providers acting as data processors who provide us with IT and system administration services. This includes but is not limited to:

(i) Organizations that assist us in verifying the identity of our app users.

(ii) Providers that aid us in providing access to your crypto assets via our app using the email account linked to your social media login used to access the app.

(iii) Artificial Intelligence (AI) providers that enable functionalities like 'conversational AI' or personalized recommendations in our app.

(iv) Rewards engine providers that help manage and allocate rewards within our app.

‍10.4 Legitimate interest refers to our business's interest in conducting and managing our operations to offer you the best service/product and the most secure experience. We ensure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you concerning specific activities by contacting us via the means outlined in paragraph 1.2.2.

‍10.5 Performance of a contract means processing your data where it is necessary for the performance of any contract we have with you or to take steps at your request before entering into such a contract.

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