Drimsim Limited
Legal
address: Room 1001, 10/F, Tower B, New Mandarin Plaza 14 Science
Museum Road, Tsimshatsui Rast, Hong Kong
Email: [email protected]
Contacts of Data Protection Officer:
Legal address: Room 1001, 10/F, Tower B, New Mandarin Plaza
14 Science Museum Road, Tsimshatsui Rast, Hong Kong
Email: [email protected]
Amendments to this Policy will be posted to https://drimsim.com/en/privacy-policy and will be effective when posted. If we’ll make any material changes
to this Policy we will notify the data subjects by email (sent to the
e-mail address specified in the account) or by means of a notice on
the website prior to the change becoming effective. Any data subject
can choose to discontinue use of our products and services if the data
subject does not accept the terms of this Policy, or any modified version
of this Policy.
We do not knowingly collect any
personal information from children under the age of 18. Our
products and services are not offered to individuals under the age
of 18.
Refusal to provide the data may result in
unavailability of provision of our products and services or poor
user experience.
Each data subject has the right to lodge a complaint to
supervisory authority in case of personal data breach, misuse or
any violation of applicable law related to personal data
processing.
Categories of Personal Data and Purposes of Processing
Contact details of our customers for the following purposes:
- to enter a contract with a customer;
- to perform a
contract with customers;
- to comply with legal obligations
on providing the data to government bodies;
- to provide
technical support as part of our contract performance;
- to
conduct marketing communications on our offerings as our
legitimate interest;
- to contact our customers for service
evaluation purposes by phone calls or other available means as our
legitimate interest.
Any marketing communication is
subject to the right to objection. The rights to objection may
also apply to other kinds of processing activities.
Technical specifications of customer’s device for the following
purposes:
- to enter a contract with a customer;
- to
perform a contract with customers;
- to comply with legal
obligations on providing the data to government bodies;
- to
provide technical support as part our contract performance;
-
to conduct marketing communications on our offerings as our
legitimate interest;
- to support availability of our
products and services;
- to improve customer experience.
Device identification and location data for the following
purposes:
- to perform a contract with customers;
- to
comply with legal obligations on providing the data to government
bodies;
- to provide technical support as part of our
contract performance;
- to support availability of our
products and services as part of our contract performance.
Information on credit cards and other payment details for
the following purposes:
- to perform a contract with
customers;
- to provide technical support and fraud detection
as part of our contract performance.
- to conduct anti-fraud
activities as our legitimate interest.
Cookie data for
the following purposes:
- to conduct marketing communications
on our offerings as our legitimate interest;
- to deliver
targeting ads by our advertisers on the basis of data subject’s
consent;
- to collect statistical information based on data
subject’s consent;
- to support availability of our products
and services as part of our contract performance;
- to
improve customer experience as part of our legitimate interest.
| Cookie title | Category | Storage period | Data processor | Description |
| Facebook Pixel | Marketing | Lifetime | Facebook | Allows to measure effectiveness and optimize ads. |
| Facebook SDK | Marketing | Lifetime | Facebook | Allows to integrate website with Facebook. |
| Google analytics | Statistical | Lifetime | Google | Allows to analyze behaviour of website users. |
| Google Tag Manager | Essential | Lifetime | Google | Allows swift connection of Google Analytics and
Yandex.Metrika with the website. |
| Yandex.Метрика | Statistical | 24 months | Yandex | Allows to obtain visual reports, recordings of user’s
activities, track traffic sources and evaluate ads
effectiveness. |
| Adspire | Statistical | 24 months | Adspire | Allows integration with CPA networks. |
| Branch.io | Statistical | 24 months | Branch.io | Provides traffic attribution and analytics. |
| FreshChat | Essential | 24 months | Freshworks Inc | Provides website messaging functionality. |
| Stripe | Essential | 24 months | Stripe | Provides payment functionality. |
| SourceBuster | Statistical | 24 months | it-agency.ru | Provides traffic source data. |
| JivoSite | Essential | 24 months | jivo.ru | Provides website messaging functionality. |
| Mango | Essential | 24 months | Mango Telecom LLC | Provides communication functionality. |
| Vkontakte | Marketing | 24 months | Vkontakte LLC | Provides individual content |
| Youtube | Essential | Up to 10 years | Google Inc. | These cookies are set by YouTube to track usage of its
services. |
| Twitter | Marketing | Up to 14 years | Twitter Inc. | These cookies are set by Twitter to track usage of its
services. |
| Linkedin | Marketing | Up to 6 months | Linkedin | These cookies are set by Linkedin to track usage of its
services. |
| Vkontakte | Marketing | Up to 24 months | Vkontakte | These cookies are set by Vkontakte to track usage of its
services and provide individual content. |
| Mail.ru | Marketing | Up to 6 months | Mail.ru | These cookies are set by Mail.ru to track usage of its
services and provide individual content. |
CHANGE COOKIE OPTIONS
Data on the customers’ communications with our products and
services for the following purposes:
- to perform a contract
with customers;
- to comply with legal obligations on
providing the data to government bodies
Passport data and personal photo for the following purposes:
- to identify the customer in order to enter a contract with a
customer;
- to comply with legal obligations on providing the
data to government bodies;
- to conduct marketing
communications on our offerings as our legitimate interest.
Profiling
We maintain profiles of our customers as it’s required to provide
our customers with history of use of our products and services.
The profile includes current balance and billing history. No
automated decision making is conducted on the basis of profile
except for the cases when our products and services may be
provided in different manner on the basis of the customer’s
balance. Insufficient balance may result in suspension of
availability of our products and services.
Recipients of Personal Data
We may share personal information with the following recipients:
- our employees;
- hosting providers;
- technical
support providers;
- partners which act as our contractors
for provision of our products and services;
- government
bodies.
We may transfer the data outside of EU and EEA
provided that the transfer is subject to model contract clauses on
international transfers of personal data.Providing information to
our data processors is subject to signing a data processing
agreement that sets out the subject-matter and duration of the
processing, the nature and purpose of the processing, the type of
personal data and categories of data subjects and the obligations
and rights of the controller.
Period of Storage
The data will be stored during the period when our products and
services are provided to the customer and as long as we have a
legal obligation to store the data in order to supply it to
government bodies.
Sensitive Information
We do not process the following information in any manner:
-
racial or ethnic origin, political opinions, religious or
philosophical beliefs, trade union membership, genetic data and
health data or data concerning a person’s sex life or sexual
orientation.
Rights of the Data Subjects
Each data subject has the following rights which may be exercised
by contacting us. All the rights below have specific exceptions in
certain cases. The requests will be processed within 30 days.
Right to access allows any data subject to request the
following information from us:
- if its data is processed;
- which data is processed;
- which are the recipients or
categories of recipients of personal data;
- data storage
period;
- existence and nature of the rights to
rectification/erasure/restriction/objection,
- existence of
the right to lodge a complaint to supervisory authorities;
-
sources of data;
- existence of profiling and automated
decision making including their logic and consequences;
-
existence of safeguards of international data transfers.
Right to rectification is the right to correct incorrect data
and the right to complete the incomplete data.
Right
to erasure (“to be forgotten”) means that the data subject may
request erasure of his or her data in the following cases:
-
the data is no longer needed for the purposes of processing;
- consent for processing is withdrawn and no other grounds of
processing apply where such processing is based on consent;
-
data subject objects to processing;
- processing is unlawful;
- the data is related to a child and was processed in the
context of offering a service directly to a child.
Right to restriction means that processing shall be restricted
if:
- the data subject claims that the data is inaccurate and
controller needs to verify if it’s really inaccurate;
-
processing is unlawful but the data subject wants processing to be
restricted rather than the data to be erased;
- processing is
no longer required for its purposes but the data subject requires
it for specific purposes;
- processing is under objection but
the controller needs to verify if objection is not overridden by
legitimate interest of the controller.
Right to
notification means that the data controller shall communicate the
request of the data subject in exercise of his or her rights to
each recipient unless it proves that it will take disproportionate
effort.
Right to data portability means that data
subject may request the data controller to provide collected data
in structured and readable form.
Right to object means
that the data subject based on its personal circumstances may
override legitimate interests of the controller which constitute
the basis for processing.
The data subject has the
right not to be subject to profiling which significantly affects
his or her interests.
Protection of Information
We take the following measures on protection of personal data to
prevent the data breaches, misuse and the violation of rights of
data subjects:
- Providing this Policy for review to any
person or entity which is about to process the personal data.
- Keeping our officers and contractors responsible for proper
data processing conducted by such officers and contractors.
-
Providing advice to any officer, data subject or partner on the
subject of compliance with this Policy.
- Making sure no
access to personal data is provided to unauthorized parties.
- Using only reliable and tested software for processing or
personal data.
- Assuming technical and organizational risks
of data processing before such processing takes place.
-
Ensuring that all actions in respect of the data are exercised by
protected accounts to access the data and all data storages are
available only to a limited number or persons on a password basis.
- Ensuring that we are able to suspend data processing or
withdraw any piece of data from processing if we believe that such
processing may violate applicable law.
- In case of change in
any business process we will determine whether such change is
data-related and check if such change falls in line with this
Policy.
- Providing that each location and device where
personal data may be stored is a safe environment.
-Utilizing
firewall to minimize the risk of unauthorized access to the
hosting infrastructure.
- Where necessary using third-party
vendors to perform security assessments to identify issues with
its data security that could result in security vulnerabilities.
- Providing encryption of most sensitive personal data.
-
Ensuring ongoing confidentiality, integrity, availability and
resilience of processing systems and services.
- Providing
the ability to restore the availability and access to personal
data in a timely manner in the event of a physical or technical
incident.
- Processing regular testing, assessing and
evaluating the effectiveness of technical and organizational
measures for ensuring the security of the data processing.
Effective: March 20, 2024
