Privacy Policy

Limited Liability Company “Sigma Software DC” (“Sigma”, “we”, “our”, or “us”), take all necessary measures to ensure that personal data is being processed by us in a lawful, fair and transparent manner.

Sigma is the data controller in respect of the personal data you provide to us when you register for and/or use any of our services provided through Dovkolo Club application (the “Services”). This privacy notice describes what personal data Sigma may process, the purpose and legal basis for the processing, your rights in relation to Sigma, as well as how you can exercise those rights.  

Sigma is committed to protecting your personal data and it is important to us to ensure that your personal data is being processed in a secure way. We are responsible for ensuring that the processing of personal data is carried out in accordance with applicable law and this privacy notice. We use appropriate technical and organizational measures with respect to the amount and sensitivity of personal data. 

It is important that you read and understand this privacy notice before you use the Services. You should not use the Services if you do not approve of this privacy notice. 

What personal data do we collect and where from?

If you register an account to use the Services, or if you contact Sigma through different communication channels, you may provide information to us that is considered personal data under applicable data protection laws. 

Sigma may process the following personal data on you: 

  • e-mail 
  • name/nickname 
  • IP address 
  • geolocation 
  • phone number 
  • contact book Apple ID/Google ID 
  • Your reviews, comments, photos and other user-generated information that you actively choose to share within the Services. 

We process data provided directly from you (e.g. when you fill in a registration form or account), other data we get on you (e.g. your IP address), data we may get from third parties if you authorize on the Services via third-party products (e.g. Google, Facebook, etc.). 

Purpose and basis for processing 

Purpose of the processing  Legal basis for the processing 
Setting-up, maintenance and managing your account  Performance of a contract  
Provision of the Service  Performance of a contract  
Receiving and responding to your communications and requests  Necessary for the performance of a contract where such communication relates specifically to the Services, otherwise legitimate interests so that we can respond to your request 
Notifying about updates to the Services, including updates to this Privacy notice and terms of use applicable to the Services  Performance of a contract – when we notify you on updates to the Services;  

Legitimate interest – when we notify you on some of our new Services and features or Services of our affiliates, as well as updates to this privacy notice or the terms of use applicable between you and us 

Preparation of statistics relating to the Services  Legitimate interest – Sigma monitors the usage of the Services to be able to improve and enhance the Services and thereby provide our users with the best experience possible  
Fixing bugs in the Services and ensuring the proper operation of the Services  Legitimate interest  
Ensuring the safety and security of the users of the Services and the safety and security of the provision of the Services  Legitimate interest 
Limiting access to the Services  Legitimate interest – in some cases, Sigma may make its Services available only to users in certain countries 

Retention of personal data

Sigma takes all reasonable steps to ensure that your personal data is processed and stored securely. Your personal data will never be stored longer than permitted by applicable law or longer than necessary to fulfil the above stated purposes. If you have created an account for using any of our Services, your personal data is saved until you delete your account.  

The above-mentioned retention periods do not apply in relation to personal data which we have a legal obligation to retain according to mandatory legislation.  

Transfer of personal data 

We do not sell the personal data to anyone else, but we may transfer personal data to other recipients as described below. We always observe great caution when transferring your personal data and your personal data is only transferred in accordance with this privacy policy and after taking appropriate security measures. 

Sigma can transfer your data: 

  • to our vendors who develop and support the Services. If we do this, we will put in place a contract with them which requires them to only process your personal data in accordance with our instructions which requires that your personal data is treated in accordance with data protection laws; 
  • to our subsidiaries and affiliated companies; 
  • to third parties, if we have a legal obligation to do so (for example, the disclosure of certain contact information about a user who has posted illegal content at the request of the copyright holder of such content); 
  • to third parties in the case of carrying out mergers and acquisitions operations with Sigma; 
  • to state and court authorities, when there are relevant legal obligations and relevant requirements. 

Please note that Sigma can disclose your personal data only where Sigma determines that doing so is permitted under the applicable data protection law. 

Transfer outside the EU 

Sigma is located in Ukraine. Under certain circumstances, personal data may be transferred to other countries outside of the EU/EEA. When such transfers are carried out, Sigma takes all appropriate measures to ensure that your personal data are adequately protected and that all processing is performed in accordance with applicable data protection laws and this privacy policy.   

Such adequate measures shall include: (a) transferring to a jurisdiction which the European Commission recognizes as providing adequate protection for the rights and freedoms of data subjects in connection with the processing of their personal data; or (b) transfers pursuant to standard contractual clauses in accordance with European Commission decisions on transferring personal data ((EU) 2021/914), provided that Sigma fulfills relevant data transfer impact assessment and implements technical, contractual and organizational additional protective measures (if the last ones are necessary).  

You have the right to obtain a copy of the safeguards that we use when transferring personal data to a country outside of the EU/EEA by using the contact information below. If you would like to get a copy of the standard contractual clauses we use, please contact us via the following e-mail: 

Your rights 

You have the following rights with respect to your data: 

  • right to request access to your personal data, i.e. to receive information on what of your personal data we are processing and how it is being used 
  • right to correct your personal data in your account settings 
  • right to erasure of your personal data  
  • right to restrict the processing of your personal data  
  • right to object to the processing of your personal data 
  • right to data portability, i.e. to have your personal data transmitted in an electronic format 

To exercise your rights, please contact us via the following e-mail: 

For the protection of your privacy and your personal data, please note that we may require that you identify yourself in connection with exercising your rights in accordance with the above. 

You also have the right to lodge a complaint with your supervisory authority if believe that our processing of your personal data is not carried out in accordance with applicable laws. 

Changes to the privacy policy 

Please note that the terms of the privacy policy may be changed or amended. Any new version will be published on Dovkolo Club application. Consequently, you should review these terms on a regular basis to make sure that you are satisfied with the changes. In case of any material changes we will, however, email you, if you have given us your email address, to make you aware of any changes made. 

Contact details  

Full legal name: Limited Liability Company “Sigma Software DC” 

Registration number: 44528239 

Address: 18 Otakara Yarosha str, Kharkiv, 61045, Ukraine 

Representative in the EU: Sigma Sweden Software AB 

If you have any questions related to this privacy notice, if you suspect that a breach of this privacy notice has occurred, or if you would like to contact us for any reason stated in this privacy notice, please contact us on: