This policy was last updated October 01, 2025.
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 inquiry. 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.
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 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 people.
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 infringing behavior.
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, while 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 below:
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 request that we update, correct or delete inaccurate or outdated Personal Data and/or that we suspend the use of Personal Data, the accuracy of which you may contest, while we verify the status of that Personal Data. We will correct your Personal Data within a reasonable time from the receipt of your written request thereof.
Deletion of Personal Data. In certain circumstances you have a right to have Personal Data that we hold about you deleted. Should you wish to have any Personal Data about you deleted, please 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 time 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 to ensure that we do not collect any further Personal Data, you should terminate your account with 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 your 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 anonymized form.
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 of 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 may delete data from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth in this Privacy Notice.
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