Iconebene, Level 7,
Office 6, Plot
441, Reduit Road,
Ebene, Cybercity,
Mauritius
www.doto.com
Privacy Policy
1. Introduction
1.1. This Privacy
Policy explains how
DOTO Global Ltd
(“Doto”, “controller”, “we,” “our” or
“us”), licensed by
Financial Services Commission,
Mauritius pursuant to
section 29
of the Securities
Act 2005 and
Rule 4 of the Securities (Licensing)
Rule 2007,
collects, uses, discloses,
and transfers
personal data that
has been provided
to us.
Personal Data about
individuals (collectively,
“users”, “data
subject” “your “or “you”)
means any information
relating to an
identified or identifiable
natural person.
1.2. Doto offers
and provides its
services to individuals
based in various
countries and as
such we are
subject to the
data protection law
in Mauritius and
in some
circumstances, to foreign data protection
law and regulations
when we deal
with a
foreign citizen.
1.3. Our Privacy
Policy must be
read together
with any legal
notices or terms
and
conditions which may
be available on
other pages of
our website. Unless
otherwise
superseded by alternative
terms and conditions
(such as in
the Client agreement),
the method is
in which the
user's personal
information is collected,
used, distributed,
and maintained will
be following this
policy.
1.4. For any
questions you can
contact our Data
Protection Officer:
privacy@doto.com.
1.5. In course
of business relations
Doto can be
qualified as a
Joint Controller with
Doto
South Africa (Pty)
Ltd. For joint
processing activities, liability is shared jointly,
according to the
signed agreement
between the legal
entities.
2. Definitions
2.1. “Controller” means
a person who
or public body
which, alone or
jointly with others,
determines the purposes
and means of
the processing of
personal data and
has
decision making power
with respect to
the processing.
2.2. “Consent” means
any freely given
specific, informed and
unambiguous indication of
the wishes of
a data subject,
either by a
statement or a
clear affirmative action,
by
which he signifies
his agreement to
personal data relating to him
being processed.
2.3. “Data Subject”
means an identified
or identifiable individual
(hereinafter referred
to
as “users” “your
“or “you”), in
particular by reference to an
identifier such as
a name,
an identification number, location data,
an online identifier
or to one or more factors
specific to the
physical, physiological, genetic, mental, economic,
cultural or
social
identity of that
individual.
2.4. “Personal Data” means any
information relating to a data subject.
2.5. “Processing” means
an operation or
set of operations performed on
personal data or
sets of personal
data, whether or
not by automated
means, such as
collection,
recording, organization, structuring, storage, adaptation or alteration,
retrieval,
Doto Global LTD (www.doto.com)
is licensed and
regulated by the
Financial Services Commission, Mauritius
as an Investment
Dealer under License
Number C119023978
Copyright © 2023.
All rights reserved.
2
Iconebene, Level 7,
Office 6, Plot
441, Reduit Road,
Ebene, Cybercity,
Mauritius
www.doto.com
consultation, use, disclosure
by transmission,
dissemination or otherwise
making
available, alignment or
combination, restriction,
erasure or destruction.
2.6. “Processor” means
a person who,
or public body
which, processes personal
data on
behalf of a
controller.
2.7. “Third party” means a
person or public
body other than
a data subject,
a controller,
a
processor or a
person who, under
the direct authority
of a controller or processor,
who or which
is authorized to
process personal
data.
3. Personal Data we
collect and hold
about you
3.1. We collect
and process
different categories of
your Personal
Data as described
below.
Purpose
Data categories
Legal Grounds
Provision of services,
including account
management
All Data, except
Audio
and Video Data,
Location
Data, Marketing and
Communication Data,
Conformity Data, Usage
Data, Technical
Data
Contract
Provision of support
services, including
communication about
possible legally
significant consequences
Identity Data
Contact Data
Profile Data
Contract
Managing users’
complaints and
resolutions
Depending on the
request, it could
be
Identity Data
Contact Data
Profile Data
Financial Data
Transaction Data
&
Purchase history
Payment Data
Contract
Doto Global LTD (www.doto.com)
is licensed and
regulated by the
Financial Services Commission, Mauritius
as an Investment
Dealer under License
Number C119023978
Copyright © 2023.
All rights reserved.
3
Iconebene, Level 7,
Office 6, Plot
441, Reduit Road,
Ebene, Cybercity,
Mauritius
www.doto.com
Economic Profile Data
KYC Data
Manage transactions
(deposits, withdrawals,
etc.)
Identity Data
Contact Data
Financial Data
Transaction Data
&
Purchase history
Payment Data
Economic Profile Data
Contract
Performing KYC/AML
checks and monitoring
transactions
Identity Data
Contact Data
Economic Profile Data
KYC Data
Special Categories of
Data/ ‘Sensitive’
Data
Conformity Data
Location Data
Legal obligation
Sharing information on
suspected financial
crimes, fraud and
threats
with law enforcement
agencies and regulatory
authority.
Identity Data
Contact Data
Economic Profile Data
KYC Data
Special Categories of
Data/ ‘Sensitive’
Data
Conformity Data
Legal obligation
Doto Global LTD (www.doto.com)
is licensed and
regulated by the
Financial Services Commission, Mauritius
as an Investment
Dealer under License
Number C119023978
Copyright © 2023.
All rights reserved.
4
Iconebene, Level 7,
Office 6, Plot
441, Reduit Road,
Ebene, Cybercity,
Mauritius
www.doto.com
Transaction Data
and
Purchase history
Profile Data
Fraud prevention
All Data, except
Audio
and Video Data,
Location
Data, Marketing and
Communication Data,
Conformity Data
Legitimate interest
To defend
against
lawsuits and claims
All Data, except
Audio
and Video Data,
Location
Data, Marketing and
Communication Data,
Conformity Data
Legitimate interest
Carrying out statistical
analysis
Profile Data
Technical Data
Usage Data
Legitimate interest
Notifying you about
changes to our
services
Identity Data
Contact Data
Legitimate interest
Improve product
support
service
Identity Data
Contact Data
Profile Data
Legitimate interest
Application and web
functionality
improvement
Usage Data
Technical Data
Legitimate interest
Marketing and product
analytics
Contact Data
Technical Data
Usage Data
Profile Data
Legitimate interest
Doto Global LTD (www.doto.com)
is licensed and
regulated by the
Financial Services Commission, Mauritius
as an Investment
Dealer under License
Number C119023978
Copyright © 2023.
All rights reserved.
5
Iconebene, Level 7,
Office 6, Plot
441, Reduit Road,
Ebene, Cybercity,
Mauritius
www.doto.com
Ensure security of
the
service from computer
attacks and users
from
unauthorized access to
data
All Data Categories
Legitimate interest
Personalization of our
services
Profile Data
Usage Data
Technical Data
Legitimate interest
Advertising (sending
information about
promotional activities and
events, etc.)
Identity Data
Contact Data
Marketing and
Communication Data
Consent
Launch targeting
advertising
Marketing and
Communication Data
Consent
4. Cookies
4.1. We and
our trusted partners
use cookies and
other technologies in
our related
services, including when
you visit our
site or access
our Services. A
"cookie" is
a
small piece of
information that a
website assign to
your device
while you are
viewing
a website. Cookies
are very helpful
and can be
used for various
different purposes.
These purposes include
allowing you to
navigate between
pages efficiently,
enable
automatic activation of
certain features,
remembering your preferences
and making
the interaction between
you and our Services quicker
and easier.
Cookies are also
used to help
ensure that the
advertisements
you see are
relevant to
you and your
interests and to
compile statistical data
on your use of our
Services.
4.2. Our website
(www.doto.com) uses the
following types of
cookies:
● 'Session cookies' which are stored only temporarily
during a browsing session
in order to
allow normal use
of the system
and are deleted from your
device when
the browser is
closed;
● 'Persistent cookies' which are read only by
our website, saved
on your
computer for a
fixed period and
are not deleted
when the browser is closed.
Such
cookies are used
where we need
to know who
you are for
repeat visits, for
example
to allow us
to store your preferences
for the next
sign-in;
Doto Global LTD (www.doto.com)
is licensed and
regulated by the
Financial Services Commission, Mauritius
as an Investment
Dealer under License
Number C119023978
Copyright © 2023.
All rights reserved.
6
Iconebene, Level 7,
Office 6, Plot
441, Reduit Road,
Ebene, Cybercity,
Mauritius
www.doto.com
● 'Third party
cookies' which are
set by other
online services who
run content on
the page you
are viewing, for
example by
third party
analytics companies who
monitor and analyze
our web access.
4.3. For more
information, please refer to the
Cookie Policy.
5. Third-party collection of
Personal Data
5.1. In course
of marketing we
use a tool
called “Google Analytics”
to collect information
about your use
of website. Google
Analytics collects information
such as how
often
users access the
services, what pages
they visit when
they do so,
etc. Google
Analytics collects the
IP address assigned
to you on the date
you visit sites,
rather
than your name
or other identifying
information. We do
not combine the
information
collected through the
use of Google
Analytics with personally
identifiable
information. Google’s ability to
use and share
information collected by
Google
Analytics about your
visits to this
site is restricted
by the Google
Analytics Terms
of
Use and the
Google Privacy Policy.
5.2. We may
also request additional
information about you
from our trusted
third parties
for AML checks
and KYC verification.
6. Sharing your Personal
Data
6.1. We do not rent, sell, or share
your Personal Data
with third parties
except as
described in this
Privacy Policy.
6.2. We may transfer or
disclose Personal
Data to our
subsidiaries, and other
affiliated
companies, and/or business
introducers to provide
the services you
have requested
and to fulfill
our contractual
obligations to you,
and to fulfill
legal and regulatory
requirements.
6.3. We may share your
Personal Data with
third parties
who process Personal
Data on
our behalf to
provide you
or us with
products or services
for the purposes
outlined
above. These third parties include:
● Professional advisers,
including lawyers, insurers, auditors, translating
agencies and tax
advisers;
● Screening services provider
and external compliance
companies, including
due diligence and
financial crime screening
databases providers;
● IT consultants and
service providers,
including hosting and
cloud services
providers;
● Card processing companies,
and payment
service providers, cloud
storage
companies;
● Other suppliers and
providers of services
to us, including
banks, our
sub-contractors agents
and other entities
within our group.
Doto Global LTD (www.doto.com)
is licensed and
regulated by the
Financial Services Commission, Mauritius
as an Investment
Dealer under License
Number C119023978
Copyright © 2023.
All rights reserved.
7
Iconebene, Level 7,
Office 6, Plot
441, Reduit Road,
Ebene, Cybercity,
Mauritius
www.doto.com
6.4. We may
disclose Personal Data,
or any information
you submitted via
the services of
we have a
good faith belief
that disclosure
of such information
is helpful or
reasonability necessary to
● Comply with any
applicable law,
regulation, legal process,
or governmental
department s
request;
● Enforce our policies
(including our agreement),
including investigations
of
potential violations thereof;
● When we consider
disclosure to be
necessary or appropriate
to prevent
physical harm or
financial loss or
in connection with
an investigation of
suspected or
actual illegal purpose;
● For the prevention, detection, investigate or take
action regarding
of any fraud
or illegal activities
or other criminal
activity;
● To establish
or exercise our
rights to defend
against legal claims;
● Prevent harm
to the rights,
property or
safety of us,
our users, yourself
or any
third party; or
● For the purpose
of collaborating
with law enforcement
agencies and/or in
case we find
it necessary in
order to enforce
intellectual property or other
legal
rights.
7. Cross-Border transfers
of your Personal Data
7.1. Where we
transfer your
Personal Data outside
of Mauritius, we
will ensure that
it is
protected and transferred in a
manner consistent with
legal requirements applicable
to the information
and where required, with your
consent.
7.2. We may put in place appropriate safeguards
(such as contractual
commitments) in
accordance with applicable
data protections laws
to ensure that
your Personal Data
is adequately protected.
7.3. We may during the
course of business
transfer and store your personal
data to a web
hosting and/or cloud
service provider,
which may be
located outside of
Mauritius.
7.4. You can request further details about
the safeguards that
we have in place in
respect
of transfers
of Personal Data
outside Mauritius.
8. Retention of your
Personal Data
8.1. We retain
your Personal Data
for the length
of time required
for the specific
purpose
or purposes for
which it was
collected. However,
we may be obliged to store
some
Personal Data for
a longer time,
taking into account
factors including:
● legal obligation(s) under
applicable law to
retain records for
a certain period
of time;
● maintain business records
for analysis and/or
audit purposes;
● defend or bring
any existing or
potential legal claims;
Doto Global LTD (www.doto.com)
is licensed and
regulated by the
Financial Services Commission, Mauritius
as an Investment
Dealer under License
Number C119023978
Copyright © 2023.
All rights reserved.
8
Iconebene, Level 7,
Office 6, Plot
441, Reduit Road,
Ebene, Cybercity,
Mauritius
www.doto.com
● deal with any
complaints regarding the
services; and
● guidelines issued by
relevant data
protection authorities.
8.2. We may
be required
to retain records for a significant period of
time (after you
are no
longer our customer)
in accordance with
certain anti-money laundering laws that
require us to
retain copies of
the documents we
used to fulfill
our obligations to
our
client as well
as supporting
evidence and records of transactions
with you.
9. Protection of your Personal Data
9.1. We take
the security of
our physical premises,
our servers
and the Website
seriously
and we take
all appropriate technical
measures using recognized security
procedures and tools in accordance
with good industry
practice to
protect your
personal information.
9.2. We use
technical and organizational security measures
in order to
protect the
Personal Data we
have under our
control against accidental
or intentional
manipulation, loss, destruction
and against access
by unauthorised persons.
10. Your Rights
10.1. Your
rights in relation
to the personal
data include:
● Right to Access:
You have
the right to request a
confirmation from us
as to
whether or not
we process your
personal data and
forward you a
copy of same.
You
also have the
right to certain other
supplementary information that
this Privacy
Policy is already
designed to address.
Please note that
there may be
circumstances
in which we
are entitled to
refuse requests
for access to
copies of personal
information. In particular, information
that is subject
to legal professional privilege
will not be
disclosed other than
to our users
and as authorised
by our users.
● Right to Rectification:
You have
the right to have your
incomplete personal
data completed.
● Right to Erasure: This provides
for the right
to have your
data erased in
case
the processing of
your personal data
is not justified.
Please note that
there may be
circumstances where you ask us to erase your personal information,
but we are
legally entitled/obliged to
retain it.
● Right to Restrict:
You have the
right to restrict the processing
of your personal
data.
● Right to Object:
In some cases,
required by
law, you
may ask us
to stop
processing your Personal Data.
● Right of Portability:
You have
the right to
receive the Personal Data concerning
you in a structured, commonly used,
and machine-readable
format and/or transmit
those Personal Data
to another data
controller.
Doto Global LTD (www.doto.com)
is licensed and
regulated by the
Financial Services Commission, Mauritius
as an Investment
Dealer under License
Number C119023978
Copyright © 2023.
All rights reserved.
9
Iconebene, Level 7,
Office 6, Plot
441, Reduit Road,
Ebene, Cybercity,
Mauritius
www.doto.com
● Withdrawal of consent:
You have
the right to
withdraw your
consent at any
point in time,
although in certain circumstances it
may be lawful
for us to continue
processing without your
consent if we
have another
legitimate reason (other
than
consent) for doing
so. Withdrawal
will not affect
the lawfulness of
processing before
the withdrawal.
● Right to Compliant:
You have
the right to lodge a
complaint regarding the
processing of your
personal data by us.
10.2. If you
want to exercise your rights
or you are unhappy with
the way in
which your
Personal Data has
been processed or
should you have
any questions regarding
the
processing of your
Personal Data,
you may refer in the
first instance to
the Data
Protection Officer,
who is available,
at the following
email address:
privacy@doto.com or you can write to
the address below:
2nd Floor,
The Catalyst,
Silicone Avenue,
40 Cybercity,
Ebene, Republic of
Mauritius.
10.3. Your
requests can be
sent to us
in a free form (in the
body of a letter, scan,
etc.) to
privacy@doto.com with your full
name and contact
information for a
quicker
processing of your
request. In
case of doubt
of your identity, we may
ask you to
justify it by
enclosing a copy
of any identity
document. If we
are not satisfied
you are
who you claim
to be, we reserve the
right to refuse
to grant your requests.
11. Changes to
this Privacy Policy
11.1. The Website
and/or any other
information displayed
on the Website
may change
from time to
time. As a
result, at times
it may be necessary for
us to make
changes
to the Website and this
Privacy Policy.
You will be
notified of important changes to
the Privacy Policy
regarding the
purposes of the
processing, the identity
of the
controller, how
rights are exercised,
and cross-border
transfers. Such notification
will
be made within
a reasonable time
before the changes
take effect.
11.2. You may request a
copy of this
privacy policy from
us using the
contact details set
out above. If
we change this
privacy policy,
the updated version
will be posted
on our
website in a
timely manner.
12. Contact us
If you have questions, complaints
or concerns regarding
the way in
which your
Personal Data has
been used, please
contact:
Data Protection Officer,
DOTO Global
Ltd,
The Cyberati Lounge,
Ground Floor,
The Catalyst,
Silicone Avenue,
Doto Global LTD (www.doto.com)
is licensed and
regulated by the
Financial Services Commission, Mauritius
as an Investment
Dealer under License
Number C119023978
Copyright © 2023.
All rights reserved.
10
Iconebene, Level 7,
Office 6, Plot
441, Reduit Road,
Ebene, Cybercity,
Mauritius
www.doto.com
40 Cybercity,
72201 Ebene,
Republic of Mauritius
Email: privacy@doto.com
Doto Global LTD (www.doto.com)
is licensed and
regulated by the
Financial Services Commission, Mauritius
as an Investment
Dealer under License
Number C119023978
Copyright © 2023.
All rights reserved.
11
