PRIVACY COMMITMENT

Most Recent Update: June 2025

1.OVERVIEW & COVERAGE OF THIS PRIVACY COMMITMENT

This privacy commitment (“Privacy Commitment”) outlines [Optival LTD] (“Entity”, “we”, “our”, or “us”) methods of collecting and handling Personal Data (defined below).
This Privacy Commitment pertains to all domains managed and run by us (including auxiliary digital resources such as microsites, advertisements, etc., collectively referred to as “platform(s)”), which offer evaluations and overviews of various third-party products and services, in addition to allowing users to effortlessly navigate and link to the sites of our affiliated third-party vendors offering such products and services (collectively, “Affiliates” and “Affiliate Portals”) (together known as “Solutions”).
This Privacy Commitment outlines the details and transparency concerning categories of Personal Data obtained from visitors interacting with, navigating, or otherwise utilizing our platform and Solutions, including digital content found therein and additional digital resources we administer (like ads, microsites, etc.) (collectively “platforms”), covering methods of interaction, reasons for collecting Personal Data and its intended use, third parties we may disclose it to and the motives for doing so, along with your legal rights and available preferences regarding your Personal Data.
This Privacy Commitment is an essential component of our Terms & Conditions (“Terms”). Any capitalized phrases not otherwise defined shall have the definitions found in our Terms.
You understand that there is no legal requirement for you to provide us with Personal Data. Yet, failing to do so may prevent us from offering some aspects of our Solutions. For instance, we require your email address to respond to direct inquiries, and additionally, specific cookies are crucial for the proper operation of our platform, while others aimed at enhancing Solutions or marketing may be opted out of. All in line with this Privacy Commitment. Should you decline data that is necessary for features within our Solution, you are free not to use those features or to refrain from visiting our platforms.
You are not under a statutory duty to share Personal Data, nor must you engage with the Site at all. By navigating the Site or engaging with the Solutions, you express agreement with this Privacy Commitment and our outlined data practices. If this Privacy Commitment is not acceptable to you, do not continue to access or otherwise engage with the Site or Solutions.
Residents of the EU/UK:
This Privacy Commitment also outlines mandatory information as per the General Data Protection Regulation (“GDPR”) including lawful justification for Personal Data handling, Data Privacy Contact, your entitlements under the GDPR and how you can invoke those rights. 

2.UPDATES

We maintain the discretion to revise this Privacy Commitment periodically, as we deem necessary. The latest Privacy Commitment will consistently be available on the platform. The updated date will be indicated by the “Last Modified” section. If mandated by applicable data rules, and in case of substantial changes, we will notify you and acquire necessary consent. Any modifications to our practices regarding Personal Data will be applicable within 7 days following the publication of the revised Commitment. We suggest you revisit this document regularly to stay informed about our privacy approach.

3. DATA HANDLER & CONTACT POINT

We take your privacy and legal rights as a data subject seriously and have assigned Prighter Group along with its regional associates to act as our privacy liaison and your official contact across these areas:

a. European Economic Area (EEA)

b. Great Britain

Prighter provides a streamlined way for you to carry out privacy requests (e.g., to retrieve or remove personal details). If you'd like to communicate with us via our designated agent, Prighter, or utilize your rights as a data subject, visit the following link: Prighter | Compliance Gateway for Optival LTD

4. INFORMATION GATHERED, INTENDED PURPOSE & LEGAL BASIS

Here you'll find insight into the categories of Personal Data we acquire, the reasons for which it's utilized, the legal reasoning for processing (under GDPR), and the definitions for both “personal” and “non-personal” data, as well as the technical treatment of each.
Types of Data Captured and Definition of Personal Data
As stipulated under applicable regulations, “Personal Data” generally includes details that point to an identifiable individual or could reasonably do so. Examples include online markers like IP addresses, cookie identifiers, names, email addresses, etc. Also included are analytical insights based on behavioral patterns, profiling, or other associated data points.
We may also obtain “Non-Personal Data”, which refers to data not linked to any specific human subject and cannot be reasonably traced back, such as consolidated usage data from our platform and Solutions, including user volume, navigation behaviors, regional statistics, visit timestamps, and technical signals from devices and browsers like operating system, device make, and browser type. This is considered Non-Personal if kept in aggregate or unlinked from any digital identifier.
When we integrate Personal with Non-Personal Data, we treat the entire dataset as Personal Data.
Source of Data
Depending on your actions on our platform and Solutions, certain data types are acquired, as clarified below. Our methods of data gathering include:

(i) automated systems and tracking methods (like cookies, tracking pixels, and tags – refer to the “Cookies and Related Tech” Section of this Commitment), either deployed by us or external entities like vendors, Affiliates, and advertising associates using third-party tools (also see table below and “Data Distribution – Types Of Third Parties Receiving Personal Data” Section of this Commitment). This also encompasses “tracking links” we embed within Affiliate assets on our platform, enabling both us and Affiliates to verify if a user (by a designated unique ID) moved from our platform to the Affiliate Portal (explained further in the below table);

(ii) user-submitted information, such as when you reach out to us directly; and

(iii) data from our Affiliates, primarily when you interact with them after being linked from our platforms).

Collected Data Types, Their Usage & Lawful Justification

The table below outlines the gathered Personal Data categories, how we process it, the specific objectives, legal reasons, and types of handling operations:
Online Tags When you visit our platform and interact with our Solutions, we gather online tags, including IP address, browser agent, and Cookie identifiers. We might also allocate a distinct user ID (a randomized alphanumeric sequence) to each visitor accessing our platform, or such identifier may be triggered upon engaging with features that redirect you to our Affiliate Portals through tracking URLs (described in the “Source of Data” section above). (together referred to as “Online Tags”).

o Geolocation Information We may also process your estimated geographic data (e.g., at the country level) derived from your IP address.

o Hardware Details We gather data sent from your device like its make and version, the browser software used to access our platform, operating system details, etc.

o Interaction Metrics We track your behavior and interaction with our platform and Solutions. This can include the pages you browsed and specific content you engaged with (like clicked items), navigation paths, timestamps for visits and activities, session duration, and more. This usage data may be archived alongside Online Tags in system logs. (collectively “Interaction Metrics”)

o ***If the information types noted above – i.e., location, device details and usage data – are connected to online tags, they will be classified and handled as Personal Data, although we may also accumulate such data in bulk for statistical purposes, which is not treated as Personal Data.

These data groups are used for the following intentions: To maintain platform functionality, ensure security, identify and prevent fraud, debug, and resolve technical faults. For analytical insights, marketing strategies, and promotional effectiveness. For instance, we use this data to understand user behavior on our platform, and to evaluate content and ad campaign performance. We also use it to personalize and enhance Solutions (such as detecting your preferred language) and to assess promotional outcomes, including retargeting strategies tied to your platform visits. Your unique ID or other Online Tags help us track user flow from our platform to our Affiliate Portals. This supports operational tracking, business performance reviews, transaction monitoring, and conversion attribution.
We handle these data sets via our internal or external cookies and tracking tools (refer to the Cookies and Related Technologies Section). We use strictly essential cookies to process data based on our business interests. We also employ additional cookies for analytical and marketing reasons contingent on your given consent through cookie settings. You may revoke your consent anytime using cookie controls on our platform.

Affiliate Engagement Insights

As earlier noted, when you engage with an Affiliate’s offer via our platform and land on their website, a tracking link will attribute a unique ID to you. We log this interaction (i.e., that you clicked and visited an Affiliate Portal) and in some arrangements, depending on our agreement with the Affiliate, the Affiliate may share back your engagement outcomes with their offer (e.g., account creation, product purchase, transaction amount, etc.)
We utilize this data for our business operations. As stated in our Terms, we are compensated by our Affiliates for directing users to their sites or generating further user actions. Thus, we analyze this data to assess earned advertising fees and for auditing purposes.
We might also process this data in aggregated form to improve our content and ad campaigns, and gain insight into user satisfaction and affiliate effectiveness (e.g., if a large number of users interact with a particular Affiliate, it may reflect quality offers). This analysis is conducted based on our legitimate interests.

Ad Campaign Response Data

When promoting our platform and Solutions, we rely on third-party services and tools for campaign management. These tools collect behavioral data such as user pathways, click timestamps, referring URLs and campaigns, and post-click engagements with Affiliates.
We gather and process this data to execute, monitor, and optimize ad performance and manage our Solutions effectively.
These data sets are used with your consent, given via the cookie preference manager. Consent may be withdrawn any time through our platform’s cookie settings.

Contact Info & User Inquiries

If you proactively reach out to us with questions about the platform, require assistance, or have other inquiries, whether via email or other communication channels, you may need to provide certain personal info such as full name, email address, and any details you choose to share. We also keep records of these communications. (collectively “User Messages”).
We use User Messages data to reply to your messages, provide requested support, or fulfill your information requests. These communications may be reviewed or stored for service improvement, internal references, or if deemed helpful for future assistance or dispute resolution.
When you initiate contact, we use User Messages data with your permission. For internal purposes, including archiving, data is processed in line with our legitimate interests.
Please be advised that the actual steps involved in processing for each purpose and lawful basis described above may vary. These typically involve automated activities such as gathering, storage, usage, transmission, deletion, or disposal. Cross-border transfers of Personal Data, as outlined in the “International Transfers” section, are done using the same legal grounds listed above.
Furthermore, certain Personal Data may be used to detect and prevent prohibited or unlawful behavior, fraud, impersonation, copyright breaches, and any other misuse of Solutions, to uphold our Terms, ensure database security, and defend against legal threats. This processing is justified by our legitimate interests.

5. COOKIES AND EQUIVALENT TRACKING METHODS

We utilize cookies (and related technologies like pixels, tags, tracking beacons, etc.) when you visit our platform or use our Solutions. Cookie usage is standard across the web. These technologies involve storing small text fragments or code on your browser or device while viewing online content. They serve many roles, including supporting page navigation, collecting analytics, and enabling ad personalization. Learn more about our cookie practices at:www.allaboutcookies.org.

Also refer to our Cookie Preferences pop-up for specific cookies used on our platform.
Cookie Management and Opt-Out Options
Aside from essential or core-function cookies, you may modify your cookie choices and opt-out of selective or all cookies at any time through our platform’s cookie manager or browser settings. Disabling some cookies may affect availability or performance of specific features and tools.

6. DATA DISCLOSURE – PARTIES WE SHARE PERSONAL DATA WITH

We share Personal Data with third parties, including reliable partners and service entities aiding in delivery and enhancement of our Solutions:

• Affiliates – Unique ID, Online Tags – If you visit an Affiliate Portal, we will share your unique ID and may, if needed for fraud defense, share IP or similar details. Such data is shared strictly for operational and conversion tracking purposes.

• Authorized agents and third-party providers – All data, as required and appropriate to the service provided – We may provide Personal Data to vetted professionals (e.g., legal or advisory teams) and service vendors (like hosting services, CRM platforms, cybersecurity vendors, etc.) who act on our behalf. These vendors are barred from using the data for anything beyond the specified services. We restrict their access to the minimum information necessary and enforce strict security obligations in line with all relevant data regulations (although vendors may use anonymized, non-personal insights independently).

• Subsidiaries, affiliates, or any acquiring entity – All data – We may share data internally within our company structure or during business transitions (such as asset sales, mergers, takeovers). In such events, data obligations and rights under this Commitment are transferred to the new controlling entity.

• Ad Technology Vendors – Online Tags, Device, Geolocation and Interaction Metrics – When we work with ad providers (e.g., Google, social networks), those providers may independently gather Personal Data via their tracking tools, merge it with other user data from across the internet, and use it for targeted ads and performance analytics. These vendors operate under their own privacy rules.

• Public authorities or legal compliance – Upon official legal demand – We may be compelled to reveal data to meet legal duties (e.g., court mandates), protect against claims, or fulfill law enforcement requirements.

7. INTERNATIONAL DATA TRANSFER

Due to our worldwide business model and service infrastructure (e.g., cloud computing), Personal Data may be stored or processed in countries different from where the user accessed the Solutions. We move data in accordance with international privacy laws, applying protective measures (e.g., legal contracts or certified frameworks like Standard Contractual Clauses) to safeguard the data during transit. If user permission is necessary under local law, using our platform implies your acceptance of such international data transfers as described herein.

8. DATA HOLDING PERIOD

As a general policy, we retain Personal Data only for the duration necessary to fulfill the intended reasons for its collection, which includes fulfilling legal, administrative, accounting, or compliance requirements. We use the following considerations to determine how long we keep the Personal Data we gather:
(i) nature of the Personal Data and its intended use: we evaluate the retention need based on the original collection purpose, the data's sensitivity, and the potential risk in the event of unauthorized access or usage;
(ii) applicable legal frameworks: the data retention period is also influenced by the laws of the relevant jurisdiction, as some laws require data retention for a fixed period. Additionally, we may keep certain types of Personal Data when legally compelled to do so, for example, via a court mandate;
(iii) disputes or legal actions: certain Personal Data may be kept if deemed reasonably necessary for defending our legal rights, managing ongoing legal threats or claims, or to enforce our terms and policies. If a dispute arises, including legal proceedings, we retain the related Personal Data until the matter is resolved.
In line with these factors – we assess when we no longer have a lawful or necessary reason to retain the data, and accordingly, once the retention period ends, the Personal Data will be erased or anonymized so that it can no longer be reasonably linked to you.
Unless bound by applicable law, we are not obligated to store your Personal Data for any specific time frame, and we reserve the right to delete it at any time, without advance notice.

9. SAFEGUARDING DATA

We enforce security protocols to minimize the risk of information loss, breaches, or improper access to Personal Data, in line with legal standards. Note that no security solution is completely impervious, and some risk always exists when handling digital Personal Data. Consequently, we cannot promise our Solutions or databases are immune from abuse, system failures, data interception, malware, or unauthorized usage. Part of information safety relies on your own device, network, and behavior, so please act accordingly to keep your data safe.

10. YOUR PRIVACY RIGHTS & OPTIONS

You are entitled to various choices, rights, and authority over your Personal Data gathered or held by us. Depending on your legal jurisdiction and relationship with us, these rights may include one or more of the key rights outlined below and steps for invoking them.
Please be aware that some rights may be executed directly by you, while others require submission of a formal request via our privacy contact: contact@DoshDealsUK.com

Residents of the EU or UK may also direct requests to our Data Privacy Representative at: Prighter | Compliance Gateway for Optival LTD

When reaching out, specify which right you wish to use and provide details that allow us to confirm your identity and link the data to you. We may also need further verification information to ensure identity before granting access or changes.

• Right to Notification – You may request clear information about how your Personal Data is collected and used. While details are found in this Privacy Commitment, feel free to reach out for further explanation using the above contact.

• Right to Access – You can ask us to confirm whether we possess Personal Data about you and to receive a copy of that data or gain access to it. Request this via the contact above.

• Right to Rectify – You may request that any incorrect or incomplete Personal Data be updated or corrected. Use the contact above to submit your request.

• Right to Erasure – You may request removal of certain Personal Data if conditions under data laws are satisfied. This is not an absolute right. We may refuse erasure in cases where data must be retained to comply with law, settle legal issues, preserve records of business interactions, execute contracts, detect security events, or exercise other legal entitlements. Submit requests as described above.

• Right to Limit Processing – You may have the right to restrict our use of your Personal Data if one of the following applies: you dispute its accuracy, request restriction instead of deletion, we no longer need the data for our processing needs, or you’ve submitted an objection pending our response. Submit requests via the provided contact.

• Right to Port Data – You are entitled to obtain a copy of your Personal Data in a portable, user-friendly format, suitable for transfer to a third party. Format of transfer is at our discretion. Requests may be submitted using the contact details above.

• Right to Revoke Consent/Object/Opt-Out – Where your Personal Data is processed with your consent, you may withdraw that consent at any time by contacting us. Some data-related rights may be exercised without contact—for instance, changing cookie settings as outlined under the “Cookies and Similar Tracking Methods” section. You also have the right to object to processing based on our business interests, but we may continue if our interest outweighs your objection or if required to enforce or defend legal claims.

• Right to Appeal or Complain If we reject a privacy request, we will inform you as required by law, including the reason for denial. Under GDPR, you have the right to submit a complaint to the Data Supervisory Authority in the EU or the UK's Information Commissioner.

11. MINORS & CHILDREN'S PRIVACY

Our Solutions are not designed for or directed to minors (a “minor” being an individual under the minimum age defined by law), and we do not knowingly collect such data. Any data received from users identified as minors will be deleted as soon as the identification is made.

12. EXTERNAL SITE LINKS

Our platform and Solutions may contain outbound links to third-party sites, including those of Affiliates. Clicking those links or using those connections may result in third parties collecting your data. We do not manage or endorse such external sites’ practices and are not responsible for their privacy behavior. To exercise your rights, you must reach out to the Business Partner directly.