Valid from 23.07.2020

This Privacy Policy describes the general principles on how dvote labs OÜ (registry code 14620143) address Sepapaja tn 6, 15551 Tallinn, Estonia with the email address [email protected] (hereinafter “Dvote”) processes Users’ Personal Data and is applicable to any person who uses, has used or has expressed intent to use the Services of Dvote. Dvote is responsible for Processing your Personal Data. All of the definitions used in and all circumstances not covered by this Privacy Policy shall be regulated by the Terms and & Conditions of Dvote and/or Regulation (EU) 2016/679.

Please read this Privacy Policy before using the Website, App and/or Services or submitting your Personal Data. 


Here you can find the meanings of the most important terms in this Privacy Policy to help you understand who and for what Dvote is Processing your Personal Data.

  • Agreement – service agreement concluded with the client.

  • App – Vocdoni App

  • Cookie(s) – small pieces of information stored by the Visitor’s browser on the hard disk of the computer of any other device of the Visitor.

  • Data Subject / you –natural person about whom we have got information or data enabling to identify the natural person. Data Subjects are our client’s representatives, Users and Visitors. Dvote does not knowingly collect or maintain personally identifiable information on the Website, App or through its Services from persons under 16 years of age, except if a guardian of such child has consented to the Processing.

  • GDPR – Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

  • Personal Data – means any information which Dvote directly relates to you (a legal or natural person or an organization legally engaged in business activities or any other business). In particular by reference to an identifier such as a name, date of birth, contact information, location data, an online identifier etc. Processing may be done manually or using automated systems.

  • Privacy Policy – this privacy policy.

  • Process or Processing – means any operation or set of operations which is performed by Dvote as part of the Services on Personal Data or on sets of Personal Data, whether or not by automated means.

  • Processor and Controller – shall have the meanings given in the GDPR.

  • Services – all services described in our Webiste or App

  • Visitor / User – is any person using the Services of Dvote.

  • Website – and all domains that Dvote may choose to use for delivering its services.


By agreeing to this Agreement or using the Services and the Website or App, you agree that the Dvote will use, disclose and Process your Personal Data in accordance with this Privacy Policy:

  1. Dvote Terms of Service and present Privacy Policy applies to communication between you and Dvote (incl. emails, phone calls, etc.) and to your use of the Website or App and Services, and establishes the policy on which Personal Data will be Processed by Dvote.

  2. Dvote may Process any information submitted, shared or exchanged to provide the Services. Dvote collects information by email, phone calls or by questionnaire or any other means. Some information may also be collected via automatic means e.g. App or Website telemetry/analytics. Dvote may also collect information from third parties e.g. verification services. Dvote shall do all that is reasonably possible to ensure the confidentiality of the Personal Data that Dvote has collected. Dvote only collect and Process Personal Data that is relevant to the purpose of the App or Website usage. This information allows Dvote to provide the Visitor/User a customized and efficient experience.

Dvote Processes Personal Data only if it has your consent to do so, or if it is necessary for providing you the Services, or Dvote has the legitimate interest to do so, or if it is required by applicable legislation. The User can choose not to provide Dvote with certain information, but then the User may not be able to take advantage of some of its main features.

  1. Dvote mainly Processes data to enable the Services offered by our App or Website (voting, live assembly meetings, etc), to comply with applicable laws, regulations and instructions, to manage the relationship between Dvote and you, to provide additional Services, to prevent illegal activities and misuse of the Service and Website or App, to ensure the quality of the Service and Website or app, etc.

  2. Dvote collects some of the information automatically. Information that is collected automatically is used with the sole purpose of improving the User experience and detecting problems of the Website or the App. Dvote may use authorised Processors and Services provided by third parties to collect and Process Data.

  3. In order to ensure the safety of your use of the Services and the Website or App and to continuously improve the quality of Services, Dvote will record and keep information about your login and use of the Service and the Website or App, but Dvote undertakes not to provide such information to any third party (unless otherwise agreed upon by both parties, or other laws and regulations).

  4. Dvote will keep tight security of all the complete comprehensive statistics regarding identity data of Dvote Visitors and will not use and/or disclose them for sale and reward. Dvote reserves the right to transmit the Personal Data to law enforcement institutions, state authorities and financial institutions if it should be required to comply with valid laws.

  5. The App collects a minimum set of anonymous telemetric data, regarding usage of the App.


Dvote only Processes your Personal Data on your consent, if there is a legitimate interest in Process Data or if it is required by valid legislation. . Except as otherwise provided in Terms of Service or present Privacy Policy, Dvote does not disclose or provide your information to third parties except in the following cases:

  1. with your explicit authorization;

  2. third parties engaged in the course of the App and Website services

  3. disclosure in accordance with the requirements of this Privacy Policy;

  4. according to the provisions of applicable laws and regulations;

  5. for the maintenance of Dvote legitimate rights and interests;

  6. to verify the authenticity of the identity of you or your representative company.


Dvote shall store your Personal Data for as long as required by law or in accordance with the law, or for the purposes stated in this Privacy Policy. Your Personal Data will be Processed no longer than necessary. The retention period of your Personal Data may be based on the applicable law (e.g. Money Laundering and Terrorist Financing Prevention Act, etc.) or legitimate interest of Dvote or Agreements signed between you and Dvote.

The data shall be retained in personal form for the duration of the business relationship and once terminated, during the term applicable by law or regulations to which Dvote is subject to the retention of the specific data.

Dvote does not sell or rent Visitor’s or User’s data to third parties. Dvote collects data so that you could use the Services.
Using forms and other means, Visitors
or Users can send data to register themselves to external organizations that use the Website or App as a participation platform. Please be aware that Dvote has no control over the content you share with these third-parties entities, and cannot accept responsibility or liability for their respective privacy policies.

The Personal Data collected by Dvote is not transmitted to countries outside the European Union or to countries that lack Personal Data protection legislation in compliance with the standards of the European Union. Data is stored in servers located in a European Union member state.

You reserve the right to demand access, correction and deletion of the data collected with your consent at all times.
After the expiration of the Personal Data storage period, Dvote shall anonymize or permanently erase your Personal Data.


If you wish to exercise any of your rights regarding Personal Data or ask questions about the Privacy Policy, please submit a corresponding request to us at [email protected] We will respond to your request by email as a rule no later than within one month. Please note that before we can provide you with the requested information regarding your Personal Data, we need to verify your identity.

You as a Data Subject have the following rights in relation to Personal Data:

  • Right of access to Personal Data – you have the right to know which of your Personal Data we store and how we Process it, including the right to know the purpose of the Processing, the persons to whom we will disclose your Personal Data, information about automated decision-making and the right to receive copies of Personal Data.

  • Right to rectification of Personal Data – you have the right to request the rectification of inadequate, incomplete and misleading Personal Data.

  • Right to withdraw the consent given for the Processing of Personal Data – you have the right at any time to withdraw the consent given to us for the Processing of Personal Data. Please note that withdrawal of your consent shall not affect the legality of the Processing that was made on the basis of consent before the withdrawal.

  • Right to erasure of Personal Data („right to be forgotten“) – you have the right to request that we erase your Personal Data (for example, if you take back the consent for the Processing of Personal Data, or if Personal Data is no longer needed for the purpose for which it was collected). We have the right to refuse the erasure of Personal Data if the Processing of Personal Data is necessary for the fulfilment of our legal obligation, to exercise the right to freedom of expression and information, for the preparation, presentation and protection of legal claims, or in the public interest.

  • Right to restriction of Processing – In certain cases, you have the right to prohibit or restrict Processing of your Personal Data for a certain period of time (e.g., if you have filed an objection to Personal Data Processing).

  • Right to object – you have the right to file an objection to Processing of your Personal Data if your Personal Data Processing takes place on the basis of our legitimate interest or public interest. You shall have the right to object at any time to Processing of Personal Data for direct marketing purposes, and we shall respond immediately.

  • Right to data portability – In case your Personal Data Processing is based on your consent and Personal Data is processed automatically, you shall be entitled to receive Personal Data about you that you submitted to us as the controller, in a structured, commonly used and machine-readable format, and you shall have the right to transmit this Personal Data to another controller. You also have the right to request that we transfer Personal Data directly to another controller, where technically feasible.

  • Submission of complaint – In case you find that your rights have been breached, you have the right to seek protection and file a complaint to the Data Protection Inspectorate.

Please read more about your rights from chapter 3 of the GDPR.


Security is of utmost importance to us. We do our best to protect Personal Data in our hands. We apply various measures (physical, technical, organizational) to protect your Personal Data from unauthorized or arbitrary rectification, disclosure, acquisition, destruction, loss or unauthorized access. If you have any information about an actual or suspected data breach, please inform us immediately at [email protected] We will deal with the issue immediately and inform the Data Protection Inspectorate (if applicable).

You can contact Dvote Data Protection Inspectorate at the following address: [email protected].


Cookies are small files text files placed on your device when you visit a Website. We use Cookies on our Website, that you can accept if you choose to use our Website. Dvote places on your device only a session-ID cookie. The cookie is used to ensure that the source of a request to a server is the same as the one through which log-in occurred. Cookies allow us to recognize whether you have used the Service before and it helps us to store your preferences and other information.

Most of the web browsers allow Cookies. Without fully allowing Cookies, not all of the functions of the Website are available to a Visitor. The allowing or prohibiting Cookies and other similar technologies shall be under the control of a Visitor via the settings of the Visitor’s own web browser. Most browsers allow you to control cookies, including turn off their acceptance by your device, through their settings’ preferences. However, if you turn off the ability of your device to accept cookies, you may lose access to this Website and the Services provided via it.

If you prefer that your Personal Data will not be Processed on our Website, you can activate the private browsing feature of your web browser.

If you access this Website without changing your browser settings, Dvote will assume that you agree to receive the cookies which Dvote or third parties place into your device when you use this Website.

You can find our Cookie Policy here.


For a better experience, while using our Website or App, Dvote may require you to enable Push notifications and give access to the Camera. This permission will only be used to scan QR codes and no data will be retained by Dvote.


Dvote would like to make sure you are fully aware of all of your data protection rights, based on the GDPR. Every Visitor can exercise their rights to access, modify, deny or restrict the handling and portability of data, as well as, revoke consent at any time given. If you have any questions or comments about this Privacy Policy, or if you would like to review, delete or update information about you or your preferences, please contact Dvote at the following address: [email protected] 


Kindly note that Dvote may modify the Privacy Policy from time to time. Please periodically visit this section to review for any changes. The modified policy will be uploaded to Webpage and App. Dvote will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

The current version: 1.2
Original version from 01.07.2020