Privacy Policy
Last Updated: November 18, 2024

Introduction
We are DREAM LEVELS LIMITED, a Cyprus company, duly registered in accordance with the laws of the Republic of Cyprus and located at 32 Patriarchou Grigoriou, 1016 Nicosia, Cyprus (hereinafter “DREAM LEVELS”, “We”, “Company”, “Us”).

This Privacy Policy (the “Privacy Policy”) describes the different ways We may collect, use, and share personal data of visitors of our website https://dreamlvl.com/ (Website)and users of our products and other services offered by us and our affiliates (the “Services”).

The Company is the controller, processors and responsible for your personal data. Being the controller, the Company independently determines the personal data processing purposes and means. This Policy is drafted in accordance with the provisions of GDPR Regulation - Regulation (EU) 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 the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR), Cypriot Law on the Protection of Natural Persons with Regard to the Processing of Personal Data and the Free Movement of Such Data of 2018 (Law 125(I)/2018), and other applicable laws and regulations.
1. WHAT INFORMATION DO WE COLLECT?
The information we collect about you depends on how you interact with us. We collect and/or create information in three main ways: A) when you provide it to us, B) automatically when you use our Services, and C) from third parties.

A. Information You Provide
We collect information depending on how you interact with the Services or website. It is all information that you provide to us directly, such as:
  • Your contact information. In our Website you can fill the gap “Contact us”, which we can use to start communication with you, including, without limitation, your email, mobile phone number, first name and surname.
  • Information that you create while using the Services (if the Services have the technical capability to do so), including, without limitation, information that you post on our website (including information that is created by you while placing requests to our support team if you have technical problems), including, without limitation, your name and surname, information about the Internet provider, information about transactions made during the use of the Service, email, mobile phone number, and other additional data that we consider reasonable to verify your Account and to fulfill your support request.

B. Information We Collect Automatically
We can collect some information automatically when you visit, access, or use the Services, such as:
  • IP address.
  • Device, hardware, and software information, including without limitation device IDs, country and language settings, User-Agent, Device Carrier, Device make, Connection Type (Wi-Fi/Cellular).
  • General location data.
  • Browser information, including without limitation your browser type and language preference.
  • Network information, including without limitation your Internet provider and/or phone network operator, network type and other identifiers characterizing the Internet service provider.
  • Information that is automatically received at the time of access to the Services with the use of cookies or similar technologies.

C. Information We Collect from Other Sources
In some cases, we may also receive information about you from service providers and third parties in connection with your use of the Services or your interactions with us on other platforms.
2. WHAT LEGAL BASIS DO WE HAVE FOR PROCESSING YOUR PERSONAL DATA?
In course of processing your personal data, we rely on one of the legal bases described below, which vary depending on the type of information we process and the context in which we collect it, such as:

2.1. Performance of our contract with you. We use the information specified in the clause 1A of the Privacy Policy to provide, manage, and administer the Services in accordance with the Terms and Conditions, as well as to enable us to fulfil our obligations to you as part of the Services including without limitation to communicate with you in order to provide you with updates and information as well as to fulfil your support request.

2.2. For our legitimate interests, namely the proper administration of our business, the monitoring and improving of our Website and Services, and the protection and assertion of our legal rights, your legal rights and the legal rights of others; and

2.3. In limited circumstances, further to your consent.
3. HOW DO WE USE INFORMATION?
In general, we use the information we collect (either individually or in combination with other information collected as described in this policy) to help us provide, improve, customize, analyze, and promote the Services to you according to Terms and Conditions.

This includes using it for purposes such as:
  • Providing the Services, as well as support and assistance for them, including by responding to inquiries, processing transactions or requests, and communicating with you (such as by sending service and account-related messages and updates);
  • Developing, delivering, and improving the Services and other offerings;
  • Personalizing your experience, including by presenting offerings or features better tailored to you or your interests, or our inferences about your interests;
  • Promoting the Services, including managing, customizing, and measuring the effectiveness of our advertisements, promotional offers, surveys, and events;
  • Conducting data analytics (like analyzing how the Services are used so we can better understand, improve, and personalize them);
  • Complying with our legal or contractual obligations and enforcing our terms.
4. HOW DO WE SHARE INFORMATION?
We may share some of the information we collect to help operate and improve the Services. Depending on how you interact with us, common examples might include sharing:
  1. If we've aggregated or de-identified the information, so that it cannot be used to identify you;
  2. If required by applicable law;
  3. Due to selling or reorganizing all or parts of our business.
  4. With third party service providers who we use in delivering our Services and Website, including certain operations and technology services;
  5. To protect our rights, our property, our users and the public,or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish our rights or defend against legal claims.
5. WHAT IS THE TERM OF DATA PROCESSING?
If you are a citizen of a European Union country, your personal data processing period ends in 5 (five) years from the termination of interaction between you and the Сompany under the agreement. The personal data storage period may be extended from 5 (five) to 7 (seven) years upon the competent authority request.

If you are not a citizen of a European Union country, your personal data processing period ends in 10 (ten) years from the termination of interaction between you and Сompany under the agreement.

In some circumstances you can ask us to delete your data. Please note that if personal data is erased at your request, we will only retain such copies of the information as are necessary to protect our or third-party legitimate interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement you have entered into with us. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
6. DATA TRANSFERS
6.1. The DREAM LEVELS and Service providers may transfer Your personal data to jurisdictions that may not provide equivalent levels of data protection.

6.2. If You are located in the EEA, in accordance with Art. 46 of the GDPR the DREAM LEVELS provides adequate protection for the transfer of personal data to countries outside of the EEA through a series of intercompany agreements based on the Standard Contractual Clauses.
7. YOUR RIGHTS
Under applicable data protection law, you have the following rights, including:

  • Right of access - You have the right to ask us for copies of your personal information.
  • Right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Right to erasure - You have the right to ask us to erase your personal information if:
a) it is no longer required in relation to the purposes for which it was gathered or processed in another way;
b) you withdraw your consent concerning processing subject to consent;
c) you are justifiably opposed to the processing;
d) it has been subject to illicit processing; or
e) it is imposed by law.

You also can independently remove personal information on your account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you.

  • Right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
  • Right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
  • Request the transfer of your personal data to you or to a third party. - We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform the Agreement with you.
  • Right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent.
  • Right not to be subject to an automated decision - We may not take a significant decision based solely on automated processing unless that decision is required or authorised by law.
  • Right to Lodge a Complaint - If you believe that we have infringed your rights, you have the right to complain to the Cypriot Data Protection Authority, which can be contacted at:
Office of the Commissioner for Personal Data Protection
Kypranoros 15, Nicosia 1061, Cyprus
Tel: +357 22818456
Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy

We highly recommend you to contact us first to seek a resolution.

In order to exercise the rights mentioned above, please contact us using the details in Section 10.
8. COOKIES
Our Website and Services uses cookies to distinguish you from other users of our Website and Services. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.

We use the following cookies:

  1. Necessary cookies. These are cookies that are required for the operation of our Website and Services. They include, for example, cookies that enable you to log into secure areas of our Website;
  2. Analytical cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website and Services works, for example, by ensuring that users are finding what they are looking for easily;
  3. Functionality cookies. These are used to recognize you when you return to our Website and Services. This enables us to personalize our content for you and remember your preferences (for example, your choice of language or region);
  4. Security cookies. They are used to ensure and improve security of our Website and Services and warrant your secure access to the Website and Services.
9. SECURITY
We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. In some cases, your information is accessible when you log into a feature we offer, and in those cases you need to keep your user credentials and password confidential and secure so that your information is protected. If we become aware of unauthorized disclosure of your personal information, we will notify you as required by law and take steps to help secure your information.
10. CONTACT US
10.1. If you have any questions, please send your inquiries to our support team at info@dreamlvl.com or send your request to us in writing to our address. Please, quote this Privacy Policy so we can deal with your inquiry efficiently. We will aim to respond to you within 15 days from receipt of your request or a shorter period as may be prescribed by the applicable law.
11. CHANGES TO THIS PRIVACY POLICY
We may change and/or update this Privacy Policy. We will post an updated version on this page if the Privacy Policy has changed. The new version is effective from the date of publication.