We at Initiative Duku, Limited (DBA Dukupay, "Dukupay" "us", "we", or "our") recognize and
respect the importance of maintaining the privacy of our customers. If not otherwise defined
herein, capitalized terms have the meaning given to them in the Terms of Service, available
at https://dukupay.com/terms (the "Terms "). This Privacy Notice describes the types of data
we collect from you when you visit our website (the "Site"). This Privacy Notice also
explains how we may process, transfer, store and disclose the data collected, as well as
your ability to control certain uses of the collected data.
Duku, Limited is the data controller in respect of the processing activities outlined in
this Privacy Notice.
"Personal Data" means any data that refers, is related to, or is associated with an
identified or identifiable individual or as otherwise may be defined by applicable law.
Privacy Notice Key Points
The key points listed below are presented in further detail throughout this Privacy Notice.
These key points do not substitute the full Privacy Notice.
Personal Data We Collect. When you register, we collect Personal Data provided by you, such
as your name and email address. We collect Personal Data regarding who invited whom to
register for our Site. We also (automatically) collect data about your use of the Site. If
you contact us for questions or complaints, we will collect the data related to your
Basis for Processing Your Personal Data. Processing your Personal Data is necessary for the
performance of the Terms and the provision of the Services to you. Processing for the
purposes of analytics and usage analysis and for our recordkeeping and protection of our
legal rights – are all necessary for the purposes of legitimate interests that we pursue.
How We Use the Data We Collect. We use the data (including Personal Data) we collect mainly
to administer and provide the Site, contact you with administrative information, including
in connection with our future payment system for which you can sign up, as well as to
improve the Site.
Sharing the Personal Data We Collect. We may share the Personal Data we collect with our
service providers (e.g. cloud computing service providers like Amazon Web Services) and
subcontractors who assist us in the operation of the Site and process the data on our behalf
and under our instructions. We ensure in our agreements with such service providers and
subcontractors that they do not make independent use of the Personal Data, such as your name
or email address. For example, we run our service on Amazon’s servers. While this means that
our users’ Personal Data is sent to Amazon, it does not, however, mean that Amazon can use
this Personal Data to advertise its products to our users. Any Personal Data transferred at
liquidation or if we sell our business, assets or shares will continue to be subject to the
provisions of this Privacy Notice.
International Transfer. We may use service
providers (e.g. cloud computing service providers like Amazon Web Services) and/or
subcontractors and/or cooperate with or have business partners and affiliates located in
countries other than your own, and send them your Personal Data. We will ensure to have
agreements in place with such parties ensuring the same level of privacy and data protection
as set forth in this Privacy Notice. You hereby consent to such international transfer.
Your Rights. Subject to applicable law and additional rights as set forth below, you may
have a right to access, update and/or delete your Personal Data and obtain a copy of the
Personal Data we have collected about you.
personalize your experience. You can adjust your settings to determine which cookies you do
or do not allow. Changing your settings and/or deleting existing cookies may affect the
Retention. We retain data for as long as necessary for the purposes set forth in this
Security. We implement industry standard measures aimed at reducing the risks of damage and
unauthorized access or use of Personal Data, but they do not provide absolute data security.
Changes to the Privacy Notice. We may change this Privacy Notice from time and encourage you
to review it periodically.
Data We Collect
We collect data from you when you choose to use our Site. In order to use our Site and/or
receive related services, you will be required to register and provide us with certain
Personal Data. We also collect Personal Data when you make use of the Site, request
information from us, sign up for newsletters or our email lists, complete online forms, or
contact us for any other reason.
Examples of the Personal Data that we collect from you may include your name and e-mail
address. Such Personal Data may be collected by us through the Site.
We also collect your browsing history on the Site.
In addition, when you use the Site, certain data may be automatically gathered about your
computer or mobile device, such as operating system, IP address, and subject to your consent
as may be required under applicable law, (geo) location, as well as your browsing history
and any data regarding your viewing on our Site. It is your voluntary decision whether to
provide us with any such Personal Data, but if you refuse to provide such data we may not be
able to register you to the Site and/or provide you with our services.
How We Use Your Personal Data
We collect your data and use it for purposes of the Site, as well as for purposes of the
future payment system that we intend to set up for such users who sign up.
We and any of our trusted third-party subcontractors and service providers may use the
Personal Data we collect from and about you for any of the following purposes: (1) to
provide you with the Site; (2) to respond to your inquiries or requests, contact and
communicate with you; (3) to contact you with informational newsletters and updates relating
to our Site and services; (4) to review the usage and operations of our Site and services;
(5) to use your data in an aggregated, non-specific format for analytical purposes (as
detailed below); (6) to prevent fraud, protect the security of our Site and services, and
address any problems with the our Site and services and (7) to provide customer support.
By analyzing all data we receive, including all data concerning users, we may compile
statistical data across a variety of platforms and users ("Statistical Data"). Statistical
Data helps understand trends and customer-needs so that new products and services can be
considered and so existing products and services can be tailored to customer desires.
Statistical Data is anonymous and aggregated and we will not link Statistical Data to any
Personal Data. We may share such Statistical Data with our partners, without restriction, on
commercial terms that we can determine in our sole discretion.
We, or our service providers or subcontractors, may use analytics tools ("Tools"), including
"Google Analytics" to collect data about the use of the Site and/or services. Such Tools
collect data such as how often users visit the Site, what pages they visit when they do so,
and what other sites and mobile applications they used prior to visiting the Site. The Tools
may collect certain Personal Data, and may link such Personal Data to specific data stored
in our customer database. We use the data we get from the Tools to improve our Site and
services. Google's ability to use and share data collected by Google Analytics about your
We may use your Personal Data as required or permitted by any applicable law.
Disclosure of Data
We may share your data, including Personal Data, as follows:
If you are invited by a friend to join the Site, we may let that friend know how many people
you have invited to join the Site as well. We will not disclose the names of those
Business Partners, Service Providers, Affiliates, and Subcontractors
We may disclose data, including Personal Data we collect from and/or about you, to our
trusted service providers (e.g. cloud computing service providers like Amazon Web Services),
business partners, affiliates, subcontractors, who may use such data to: (1) help us provide
you with the Site and/or services; and (2) aid in their understanding of how users are using
our Site and/or services. We ensure in our agreements with our service providers and
subcontractors that they do not make independent use of the Personal Data, such as your name
or email address.
We may use subcontractors and service providers and have business partners (e.g. cloud
computing service providers like Amazon Web Services) and affiliates who are located in
countries other than your own and send them data we receive (including Personal Data). We
will ensure that these third parties will be subject to written agreements ensuring the same
level of privacy and data protection as set forth in this Privacy Notice. You hereby consent
to such international transfer.
We may transfer our databases containing your Personal Data if we sell our business or part
of it, including in cases of liquidation. Data about our users, including Personal Data, may
be disclosed as part of, or during negotiations of, any merger, sale of company assets or
acquisition and shall continue being subject to the provisions of this Privacy Notice.
Law Enforcement Related Disclosure
We will fully cooperate with any law enforcement authorities or court order requesting or
directing us to disclose the identity, behavior or (digital) content and data of or related
to an individual, including in the event of any user suspected to have engaged in illegal or
We may also share your Personal Data with third parties:
(I) if we believe in good faith that disclosure is appropriate to protect our rights,
property or safety (including the enforcement of the Terms and this Privacy Notice);
(II) to protect the rights, property or safety of third parties;
(III) when required by law, regulation subpoena, court order or other law enforcement
related issues; or
(IV) as is necessary to comply with any legal and/or regulatory obligation. You can request
such Personal Data as specified herein by emailing us at [email protected]
How We Protect Data
We make efforts to follow generally accepted industry standards to protect the Personal Data
submitted to us, both during transmission and once we receive it. However, no method of
transmission over the Internet, or method of electronic storage is 100% secure. Therefore,
we strive to use commercially acceptable means to protect your Personal Data, we cannot
guarantee its absolute security.
How to Access and Limit Our Use of Certain Data
You have certain rights in relation to the Personal Data that we hold about you, as detailed
below. We reserve the right to ask for reasonable evidence to verify your identity before we
provide you with any information and/or comply with any of your requests, as detailed
Right of Access and Data Portability. You have a right to know what Personal Data we collect
about you and, in some cases, to have the data communicated to you. Subject to the
in applicable law, you may be entitled to obtain from us a copy of the Personal Data you
provided to us (excluding data that we obtained from other sources) in a structured,
commonly-used, and machine-readable format, and you may have the right to (request that we)
transmit such Personal Data to another party. If you wish to exercise this right please
us letting us know what data in particular you would like to receive and/or transmit.
applicable law, we may charge you with a fee. Please note that we may not be able to provide
with all the data you request, for instance, if the data includes Personal Data about
person. Where we are not able to provide you with data that you have asked for, we will
to explain to you why. We will try to respond to any request for a right of access as soon
Right to Correct Personal Data. Subject to the limitations in applicable law, you may
that we update, correct or delete inaccurate or outdated Personal Data and/or that we
the use of Personal Data, the accuracy of which you may contest, while we verify the status
that Personal Data. We will correct your Personal Data within a reasonable time from the
of your written request thereof.
Deletion of Personal Data. In certain circumstances you have a right to have Personal Data
we hold about you deleted. Should you wish to have any Personal Data about you deleted,
contact us, using the contact information specified in this Privacy Notice. Subject to
applicable law, we will delete Personal Data provided to us by a user within a reasonable
from the receipt of a written (including via email) request by such user to delete such
collected Personal Data. We cannot restore data once it has been deleted. Please note that
ensure that we do not collect any further Personal Data, you should terminate your account
us by pressing the “Delete Account” button on the Site and clear our cookies from any device
where you have accessed our Site. We may retain certain Personal Data (including following
request to delete) for audit and record-keeping purposes, as well as other purposes, all as
permissible and/or required under applicable law. We may also retain your data in an
Account Deactivation. You can delete your account with us by pressing the “Delete Account”
button on the Site.
Right to Object. Subject to applicable law, you may have the right to object to processing
your Personal Information for certain purposes.
Supervisory Authority. If you are a European Citizen, you may have the right to submit a
complaint to the relevant supervisory data protection authority.
Subject to applicable law, we retain data as necessary for the purposes set forth above. We
delete data from our systems, without notice to you, once we deem it is no longer necessary
the purposes set forth in this Privacy Notice.
Cookies and Similar Technologies
"persistent" cookie may be used to help save your settings and customizations across visits.
Third parties through which we provide the Services and/or our business partners may be
and reading cookies on your browsers, or using web beacons to collect information in the
of advertising being served on different websites.
How to Adjust Your Preferences
Most Web browsers are initially configured to accept cookies, but you can change this setting
your browser either refuses all cookies or informs you when a cookie is being sent. In
you are free to delete any existing cookies at any time. Please note that some features of
Services may function improperly when cookies are disabled or removed.
Third-Party Applications and Services
All use of third-party applications or services is at your own risk and subject to such third
party's privacy policies.
Please note that we reserve the right to send you service-related communications, including
service announcements and administrative messages relating to your account, without offering you
the opportunity to opt out of receiving them. Should you not wish to receive such communications
you may cancel your account.
We do not knowingly collect personally-identifiable data from children under the age of eighteen
(18). In the event that you become aware that an individual under the age of eighteen (18) has
enrolled without parental permission, please advise us immediately.
When visiting this Site, you shall be asked to accept the terms of this Privacy Notice. If you
do not agree with the terms hereof, please do not use the Site. We may update this Privacy
Notice from time to time – we encourage you to review it periodically. By continuing to access
or use the Site and/or services after those changes become effective, you agree to be bound by
the revised privacy notices. We will post the updated Privacy Notice on this page. Please come
back to this page every now and then to make sure you are familiar with the latest version. Any
new Privacy Notice will be effective from the date it is accepted by you.
Comments and Questions
or delete your Personal Data, please contact us at [email protected]
Last updated: June 2021.