This website/mobile application DOMA is operated by DOMA Expert Corp., located in Delaware, USA, 108 W. 13th Street, Suite 100 registered under the Employer Identification Number (EIN) 992460026.

This Privacy Policy governs the collection, use, and protection of personal data by DOMA Expert Corp. in alignment with U.S. Federal Law, Delaware State Law, and the General Data Protection Regulation (GDPR) to ensure the rights of our clients in the European Union.

Important: by providing personal data to DOMA and/or through the website/ mobile application, the user authorizes that their personal data be used and processed by DOMA under the terms and conditions described below.

1. Scope

This Privacy Policy covers the DOMA mobile application/website owned by DOMA Expert Corp..

DOMA is accessible through the mobile application available on Google Play and App Store.

2. Warning

Browsing, registering, and using the DOMA platform is subject to acceptance of the conditions set out in this policy. If you do not agree with it, you must leave the mobile application.

3. Privacy and Security Policy

DOMA cares about your privacy and protects the information transmitted to it.

DOMA establishes compliance with the principles of legislation and data protection, respecting all national laws and regulations.

Links to third party websites may be made available on these platforms for greater user convenience. DOMA is not responsible for, approves or in any way supports or subscribes to the formal content of these websites or the websites linked or referred to in them.

DOMA is not responsible for any users of this website for any damages arising from the use or disclosure of the information contained therein.

4. Cookies

4.1. What are cookies?

"Cookies" are a text string stored in a specific file and included in Hypertext Transfer Protocol (HTTP – Hypertext Transfer Protocol) requests and responses.

It allows the recording of status information while browsing and when returning to a specific website, maintaining HTTP sessions.

4.2. Why are Cookies used?

For websites to work more effectively and quickly;

To improve the level of security when using an area with restricted access;

Help collect information that can best serve your interests;

Collect statistical information to improve the way we relate to customers and products.

4.3. Benefits for the customer or user

More security

Do not repeatedly receive questions or information already viewed;

Disadvantages some cookies may remain installed in the user's browser for some time, and in addition, there are cookies that can monitor the user's journey through the companies' website.

What type of cookies does DOMA use?

Essential - mandatory for the website to function properly (user login, for example);

Non-essential - Does not disrupt the proper functioning of the website, but is used to improve user interaction;

Low-intrusive - used to observe the user, but does not provide any type of personal information (Google Analytics);

Highly Intrusive Cookies - These are used to collect detailed user behavior and personal data. We use these cookies only with your explicit consent and ensure that the data collected is handled securely and in accordance with GDPR.

cookie	Designation	Description	Other information
Google Analytics	_gid _ga _gac_	These cookies are intended to collect information about how visitors use the website. The information collected is intended to help improve the website, and all information collected is strictly anonymous	For more information visit the website: https://mark etingplatform.google.com /about/
User Session	PHPSESSID	This cookie is intended to record the user's session, allowing them to be logged in whenever they access secure areas such as the customer area, thus preventing this information from being requested repeatedly on each page they browse. This cookie only exists as long as the user is logged in.
Mixpanel	mp_e58842e23 01dca30326afa9 5a6801883_mix panel
Google Tag Manager	_dc_gtm_
	__ar_v4
	zuid
	CookieIntro

Use of Cookies by DOMA

All browsers allow you to accept, reject, or delete cookies by changing the parameters of your Internet browser. Changing the parameters can be done through the specific settings of your internet browser. We warn you that refusing cookies may slow down access to the website and prevent access to certain areas of the website.

For more information about cookies, including finding out which cookies have been set and how they can be managed and deleted, visit www.allaboutcookies.org.

If you do not wish to be detected when visiting our website, you can do so using the link https://tools.google.com/dlpage/gaoptout.

You can find information about controlling cookies according to your Internet browser in the following table:

Type of Internet Browser	site
Microsoft Edge	https://support.microsoft.com/pt-PT/microsoft-edge/63947406-40ac-c3b8-57b9- 2a946a29ae09
Chrome	https://www.google.com/intl/en-GB/chrome/more/privacy.html
Firefox	https://support.mozilla.org/en-US/kb/Clear%20Recent%20History
Safari	https://support.apple.com/kb/PH5042
Opera	https://security.opera.com

5. Processing of Personal Data

5.1. What is personal data?

“Personal data” is any information that can identify you either directly (for example, your name) or indirectly (for example, data presented under a pseudonym, such as a unique identification number).

5.2. What data do we collect about you and how do we use it?

DOMA may collect your data under a legal or regulatory imperative, a contractual relationship, its legitimate interest (in order to improve its products and services), and/or informed consent.

5.3. Who can access your personal data?

We may share your personal data to comply with legal or contractual obligations, to improve our products and services, or after obtaining your consent.

Depending on the purpose for which they are collected, and exclusively on a need-to-know basis, DOMA may have access to some of your personal data; whenever possible, the data is presented under a pseudonym (not allowing direct identification), and whenever necessary to provide you with the requested services.

We share your data with external entities that provide IT services, such as hosting and maintenance, and with our business partners. We ensure these entities adhere to strict data protection and confidentiality terms. A list of these third parties and the purposes for sharing are available upon request.

There are external entities that assist DOMA in providing IT services, such as WEB hosting and maintenance services, as well as software and applications that may contain data about you (such services may sometimes involve access to your data to carry out the necessary tasks).

From time to time, we may disclose your personal data to other entities, as part of the services provided. In these cases, we require that these entities in question have in place appropriate technical and organizational measures to guarantee the security of your information to protect your personal data.

5.4. Where do we store your personal data?

The data we collect from you and for which we are responsible is stored at a location in the European Union.

5.5. How long do we keep your personal data?

Personal data collected for account management will be retained as long as you maintain an account with us and for a period of six years thereafter to handle any residual issues or queries. We only store your personal data for as long as necessary to achieve the purpose associated with processing it. To determine the data retention period, we use the following criteria:

● When you register on the DOMA website/app, we will store your data for as long as you are our customer.

● When you submit an application to work at DOMA, the data you provide will be kept for a period of two years.

● When cookies are placed on your computer, DOMA will keep them for as long as necessary to achieve its objectives (for example, session identification cookies) defined in the cookies chapter;

● When you send the documents required for verification and validation of accounts, we will keep them long enough to fulfill your objective. After that, they will be completely deleted from all of our systems.

DOMA may retain some of your personal data to comply with its legal or regulatory obligations, as well as to administer your rights (for example, to enforce petitions in Court) or for statistical or historical purposes.

When the use of your personal data is no longer necessary, it will be removed from the DOMA system or kept anonymous so that you cannot be identified from the data.

DOMA is committed to keeping your personal data secure and takes all appropriate precautions to do so. As such, it is contractually required

that trusted external entities that process your personal data on our behalf do the same.

5.6. General Information about the Processing of your data

personal data	Goal	Foundation	Responsible for treatment
Name, Email	Access to the Client Area	Contractual obligation	Doma
Name, Surname, Mobile phone, Email, CV	Reception of Applications	Legitimate interest	Recruiter Box
Email	Respond to contact request	Consent	Doma
IP, browser, etc.	Tracking visits via Google Analytics	Legitimate interest	Doma
Use of cookies	Access metrics about visitors in order to understand, in a generic way, who the visitors are	Legitimate interest	Doma
Payment data	To proceed with payment for the services offered	Contractual obligation	Stripe Paypal Hipay
Identification document data	Profile validation for greater user security	Consent	Doma
Tax Identification Number	Profile validation for greater user security	Consent	Doma
Address (Proof)	Profile validation for greater user security	Consent	Doma

personal data	Goal	Foundation	Responsible for treatment
Civil liability insurance details	Profile validation for greater user security	Consent	Doma
Work accident insurance data	Profile validation for greater user security	Consent	Doma
Criminal record	Profile validation for greater user security	Consent	Doma
Data associated with Professional Licenses	Profile validation for greater user security	Consent	Doma

5.7. Your Rights and Choices

DOMA respects your right to privacy and the protection of your data: it is important that you are able to control your personal data.

You have the following rights:

Your Rights

● The right to be informed: You have the right to obtain clear, transparent, and easily understandable information about how we use your personal data and about your rights. It is for this reason that we provide you with information in this Policy.

● The right of access: You have the right to access the personal data we hold about you (subject to certain limitations). We may charge a reasonable fee taking into account the administrative cost of providing the information. Manifestly unfounded, excessive, or repetitive requests may not be responded to.

● The right to rectification: You have the right to rectify your personal data if it is incorrect or out of date and/or to complete it if it is incomplete. To do this, use the editing capability of your DOMA profile.

● The right to erasure/right to be forgotten: In some cases, you have the right to have your personal data erased or deleted. Please note that this is not an absolute right, as we may have legal or legitimate grounds for retaining your personal data. If you want us to delete your data, please contact us using the details below or use the functionality on our platform.

● The right to object to direct marketing, including profiling: You can unsubscribe or opt out of our direct marketing communications at any time. The recommended way to do this is to deactivate this option in the dedicated “Notifications” space.

● The right to withdraw consent to consent-based data processing at any time: You can withdraw your consent to our processing of your data when such processing is based on your consent. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

● The right to object to processing based on legitimate interests: You can object to the processing of your data at any time when said processing is based on a legitimate interest. We refer to the table inserted in the section “what data do we collect and how do we use it”, especially the column “What is the legal basis for processing your data?” to identify when our processing is based on legitimate interests.

● The right to lodge a complaint with the supervisory authority: You have the right to contact the data protection authority in your country to lodge a complaint against DOMA´s data protection and privacy practices. Do not hesitate to contact us with the details mentioned below before filing any complaint with the competent data protection authority, namely the National Data Protection Commission.

● The right to data portability: You have the right to move, copy or transfer data from our database to another. This only applies to data you have provided, when the processing is based on your consent or on a contract and the processing is carried out by automated means.

To exercise your rights under GDPR, such as accessing, rectifying, or requesting the deletion of your personal data, please contact our privacy team at hello@doma.expert.

6. Data Transfer

Personal data collected within the European Union may be transferred to, and processed in, countries outside of the EU.

We transfer personal data collected within the EU to third countries only when necessary. Such transfers are performed in compliance with GDPR, using Standard Contractual Clauses to ensure that your data receives an adequate level of protection.

We ensure such transfers comply with legal requirements by using Standard Contractual Clauses approved by the European Commission. These clauses require data recipients to protect data they process from the EEA in accordance with European Union data protection law. Our procedures regarding data transfers are regularly reviewed to ensure compliance.

6.1 Chat Conversation Storage

At DOMA, we are committed to providing a seamless and efficient platform for communication between service providers through our chat service. This service aims to facilitate collaboration, enhance the provision of services, and maintain a comprehensive record of relevant transactions.

As part of our dedication to transparency and user privacy, it is essential for us to outline our practices regarding the collection and storage of conversations within the chat. This privacy policy clause elaborates on how your data is handled during your use of the chat service, emphasizing the importance of protecting your information and ensuring compliance with privacy regulations, particularly the General Data Protection Regulation (GDPR).

Please read the following clause carefully to understand how your chat conversations are collected, processed, and stored. By continuing to use our chat service, you signify your consent to the terms outlined in this policy.

6.1. Collection and Purpose

By using our chat service, you acknowledge and agree that conversations may be collected and stored by us. This collection is carried out for the purpose of facilitating communication between service providers, ensuring effective service provision, and maintaining a relevant transaction history.

6.2. Data Collected

The data collected during conversations may include profile information, contact details, exchanged messages, and details related to service provision. This information is strictly necessary to fulfill the mentioned purposes.

6.3. Consent

By using our chat service, you expressly consent to the collection and storage of conversations as described in this policy. You have the right to withdraw your consent at any time by contacting us hello@doma.expert, but please note that this may affect the functionality of the service.

6.4. Retention Period

Conversations will be retained for the period necessary to fulfill the purposes for which they were collected, unless a longer retention is required by legal or regulatory obligations.

6.5. Data Security

We have implemented appropriate security measures to protect your conversations against unauthorized access, alteration, disclosure, or unauthorized destruction.

6.6. Data Subject Rights

You have the right to access, correct, or delete your conversations. To exercise these rights or for any privacy-related queries, please contact us.

7. Changes to the Policy

We reserve the right to modify this privacy policy. Significant changes will be communicated appropriately.

By using our chat service, you are aware of and agree to the terms of this chat conversation storage clause. We recommend periodically reviewing this policy to be aware of any updates.

We will notify you of any significant changes to our privacy policy by posting a notice on our website and, where appropriate, by sending you an email notification.

8. Other General Provisions

DOMA reserves the right, at any time and without prior notice, to change this Privacy Policy, but undertakes to notify all its users at a later stage.

9. Contacts

For any questions related to this Privacy Policy and to exercise any of the rights referred to above, you can contact DOMA's Data Protection Officer via: hello@doma.expert