EU Privacy Policy (GDPR Addendum)

Introduction

DolRise is committed to protecting user privacy worldwide. This EU Privacy Policy Addendum explains how DolRise complies with the General Data Protection Regulation (GDPR) for individuals located in the European Union (EU) and the European Economic Area (EEA).

This Addendum applies only to users who are subject to the GDPR and should be read together with DolRise’s Global Privacy Policy. Where this Addendum provides additional or specific information required by EU law, it supplements the Global Privacy Policy rather than replacing it.

The GDPR is designed to strengthen individual rights over personal data and to ensure that organizations process personal data lawfully, fairly, and transparently. DolRise aligns with these principles by minimizing data collection, limiting data retention, and designing systems that respect user autonomy.

Under the GDPR, individuals have enhanced rights regarding how their personal data is collected, used, and controlled. DolRise recognizes these rights and has implemented processes intended to support transparency, accountability, and user choice.

DolRise’s approach to privacy emphasizes data minimization by default. Wherever possible, features are designed to function without requiring long-term storage of personal information. Algorithmic systems are subject to time-based limits and are designed to avoid permanent profiling.

This Addendum outlines how DolRise meets its obligations under the GDPR, explains the rights available to EU users, and describes how users may exercise those rights or contact DolRise with questions or concerns.

By providing this Addendum, DolRise seeks to ensure that EU users clearly understand their rights and the safeguards in place to protect their personal data, in accordance with applicable EU law.

Scope & Applicability

This EU Privacy Policy Addendum applies solely to individuals who are located within the European Union (EU) or the European Economic Area (EEA) and who use or interact with DolRise’s services.

This Addendum supplements DolRise’s Global Privacy Policy and does not replace it. The Global Privacy Policy continues to apply to all users worldwide, while this Addendum provides additional disclosures and rights required under the General Data Protection Regulation (GDPR).

This Addendum applies where the GDPR governs the processing of personal data, including situations in which DolRise offers its services to individuals in the EU or monitors usage related to services accessed from within the EU or EEA.

If you are located outside the EU or EEA, this Addendum does not apply to you directly. In such cases, the Global Privacy Policy and any applicable regional privacy policies govern DolRise’s data processing activities.

DolRise does not seek to avoid the application of the GDPR through technical or organizational arrangements. Where the GDPR applies, DolRise processes personal data in accordance with its requirements, including principles of lawfulness, fairness, transparency, data minimization, and purpose limitation.

In the event of any inconsistency between this EU Privacy Policy Addendum and the Global Privacy Policy with respect to EU users, this Addendum shall prevail to the extent required by applicable EU law.

Legal Basis for Processing

The General Data Protection Regulation (GDPR) requires that personal data be processed only where a valid legal basis applies. DolRise processes personal data in accordance with this requirement and does not collect or use personal data without a lawful justification.

In many cases, DolRise relies on your consent as the legal basis for processing. This means that where you choose to provide information or use certain features, you do so voluntarily after being informed about how your data may be used. You may withdraw your consent at any time, and such withdrawal will not affect the lawfulness of processing carried out before it.

DolRise may also process personal data where it is necessary for the purposes of its legitimate interests. These interests include operating and securing the platform, preventing abuse, improving service reliability, and ensuring that features function as intended. When relying on legitimate interests, DolRise carefully balances its interests against your fundamental rights and freedoms.

In certain circumstances, DolRise may process personal data in order to comply with a legal obligation. This may include responding to lawful requests from public authorities or meeting regulatory requirements where applicable law requires such processing.

DolRise does not process special categories of personal data, such as sensitive health or psychological data, for commercial purposes. Algorithmic systems related to user experience are designed to operate with time-based limits and do not create permanent personal profiles.

In line with the principle of data minimization, DolRise processes only the personal data that is necessary for the purposes described and seeks to limit both the scope and duration of data processing wherever possible.

Your Rights under the GDPR

The General Data Protection Regulation (GDPR) grants individuals specific rights designed to give them greater control and understanding over how their personal data is processed. DolRise respects these rights and recognizes them as a core component of responsible and lawful data handling.

Under the GDPR, individuals are not merely users of a service but owners of their personal data. This means that personal data must be processed transparently, fairly, and only for clearly defined purposes.

These rights are intended to ensure that individuals can understand what data is processed about them, request access to that data, correct inaccuracies, and in certain circumstances limit or object to how their data is used.

DolRise designs its systems to support these rights in practice, not only in principle. This includes minimizing long-term data storage, avoiding permanent profiling, and providing meaningful user choice where data processing occurs.

It is important to note that GDPR rights are not absolute. In some cases, limitations may apply where processing is required by law or necessary to protect the rights and freedoms of others. Any such limitations are applied only where permitted under applicable law.

The following sections describe each GDPR right in more detail and explain how you may exercise these rights in relation to your use of DolRise.

Right to Be Informed

Under the GDPR, individuals have the right to be informed about how their personal data is collected and used. This right is a foundational principle of transparency and supports the exercise of all other data protection rights.

DolRise provides clear and accessible information about its data processing practices, including the types of personal data that may be processed, the purposes for which data is used, and the legal bases relied upon under applicable law.

This information is made available through publicly accessible privacy notices and related documentation that do not require a user account or authentication to access. DolRise seeks to present this information in plain language and avoid unnecessary technical or legal complexity.

Where personal data is collected directly from an individual, DolRise aims to provide relevant privacy information at or before the time of collection. Where personal data is obtained indirectly, DolRise provides information within a reasonable timeframe, in accordance with applicable legal requirements.

If there are material changes to how personal data is processed, DolRise updates its privacy disclosures to reflect those changes. Such updates are intended to ensure that individuals remain informed and can make meaningful choices regarding their use of the platform.

Right of Access

Under the GDPR, individuals have the right to obtain confirmation as to whether DolRise processes their personal data and, where such processing occurs, to access that personal data.

This right allows individuals to understand what personal data is held about them, the purposes for which it is processed, and how such processing relates to their use of the DolRise platform.

Upon request, DolRise may provide information regarding the categories of personal data processed, the general purposes of processing, and other relevant contextual details, subject to applicable legal limitations.

The right of access does not apply without restriction. In certain circumstances, DolRise may limit the information provided where disclosure would adversely affect the rights and freedoms of other individuals or conflict with legal obligations.

DolRise seeks to respond to access requests within the timeframes required by applicable law and to present information in a clear and understandable format.

Right to Rectification

Under the GDPR, individuals have the right to request the correction of personal data that is inaccurate, incomplete, or outdated. This right helps ensure that personal data processed about an individual remains accurate and reliable.

DolRise recognizes that personal data may change over time and provides mechanisms for individuals to request updates or corrections where appropriate. Where inaccuracies are identified, DolRise seeks to rectify such data without undue delay.

In certain circumstances, DolRise may be required to retain specific records in order to comply with legal obligations or protect the rights and safety of others. In such cases, the scope of rectification may be limited as permitted by applicable law.

Right to Erasure (Right to Be Forgotten)

The GDPR provides individuals with the right to request the deletion of their personal data in certain circumstances. This right is commonly referred to as the “right to be forgotten.”

Individuals may request erasure where personal data is no longer necessary for the purposes for which it was collected, where consent has been withdrawn, or where processing is otherwise unlawful under applicable data protection law.

DolRise is designed with data minimization principles in mind and implements time-based limits that reduce long-term data retention wherever possible. Where erasure requests are valid, DolRise seeks to delete personal data without undue delay.

The right to erasure is not absolute. DolRise may retain certain information where retention is required by law, necessary to protect the rights of others, or needed to maintain platform security and integrity, as permitted under the GDPR.

Right to Restrict Processing

Under the GDPR, individuals have the right to request the restriction of processing of their personal data in certain circumstances. This right allows data to be retained while temporarily limiting how it is actively used.

Individuals may request restriction where the accuracy of personal data is contested, where processing is considered unlawful but erasure is not desired, or where the data is no longer needed by DolRise but is required by the individual for the establishment, exercise, or defense of legal claims.

Where processing is restricted, DolRise will limit the use of the affected data to storage or other permitted purposes under applicable law, until the restriction is lifted or resolved.

Right to Data Portability

The GDPR provides individuals with the right to receive certain personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another service provider where technically feasible.

This right applies to personal data that is processed based on consent or the performance of a contract and that is processed by automated means.

Due to DolRise’s data minimization practices and time-limited data retention, the scope of portable data may be limited. Where applicable and legally required, DolRise will make reasonable efforts to provide data portability in accordance with GDPR requirements.

Right to Object

Under the GDPR, individuals have the right to object to certain types of processing of their personal data. This right applies in particular where processing is based on legitimate interests or is carried out for analytical or statistical purposes.

Where an objection is raised, DolRise will assess whether there are compelling and lawful grounds to continue processing or whether processing should be restricted or stopped in relation to the specific data concerned.

DolRise respects user choice and provides mechanisms that allow individuals to reduce or disable certain forms of personalization, including the option to use neutral or non-personalized feeds.

This right is not absolute. DolRise may continue processing where required to comply with legal obligations, protect platform security, or safeguard the rights and freedoms of others, as permitted under the GDPR.

Automated Decision-Making and Profiling

The GDPR provides protections against decisions based solely on automated processing, including profiling, where such decisions produce legal or similarly significant effects on individuals.

DolRise does not engage in automated decision-making that produces legal or significant effects on individuals. Our systems are designed to support content organization and emotional balance, not to make determinations about a person’s rights, opportunities, or identity.

DolRise does not create permanent behavioral or emotional profiles. Any contextual or emotion-related signals are session-limited, subject to time-based decay, and are not retained as long-term personal histories.

Where automated processing is used to improve the user experience, individuals retain the right to request additional information, seek human review where applicable, or opt out of certain algorithmic features in accordance with applicable law.

International Data Transfers

DolRise operates as a global platform. As a result, certain technical operations or service functions may involve the processing of personal data outside the European Union (EU) or the European Economic Area (EEA).

Where personal data of EU users is transferred or processed outside the EU or EEA, DolRise ensures that such transfers are conducted in accordance with the requirements of the General Data Protection Regulation (GDPR).

DolRise relies on appropriate safeguards to protect personal data during international transfers. These safeguards may include legally recognized transfer mechanisms, contractual protections, and technical or organizational security measures designed to maintain an equivalent level of data protection.

International data transfers may occur for purposes such as maintaining platform reliability, ensuring system security, providing infrastructure support, or complying with applicable legal obligations. In all cases, transfers are limited to what is necessary for these purposes.

DolRise follows a principle of data minimization and seeks to reduce the need for cross-border data transfers wherever possible. Systems are designed to limit long-term data storage and avoid unnecessary replication of personal information across jurisdictions.

DolRise does not transfer personal data for commercial resale or unrelated third-party use. Any international processing of personal data remains subject to the protections described in this Addendum and in the Global Privacy Policy.

EU users may contact DolRise for additional information about international data transfers or the safeguards applied to such transfers, as described in the Contact section of this policy.

Data Retention

DolRise retains personal data only for as long as necessary to fulfill the purposes for which it was collected, in accordance with the principles of the General Data Protection Regulation (GDPR).

Our data retention practices are guided by the principles of purpose limitation, data minimization, and storage limitation. This means that personal data is not kept longer than required to provide the service, maintain platform security, or comply with applicable legal obligations.

DolRise does not maintain permanent emotional profiles or long- term behavioral histories about users. Algorithmic signals used to adjust user experience are designed to be temporary and are subject to time-based expiration and decay.

Where personal data is no longer necessary for its original purpose, DolRise applies appropriate measures to delete, anonymize, or de-identify such data, depending on technical and legal requirements.

Certain technical or security-related information may be retained for a limited period to protect the integrity of the platform, prevent misuse, or comply with legal obligations. Such data is handled under strict access controls and retention limits.

EU users have the right to request additional information about data retention practices or to exercise their rights under the GDPR, including the right to erasure, where applicable.

By limiting data retention and avoiding unnecessary storage of personal information, DolRise seeks to reduce privacy risks and uphold its commitment to user trust and regulatory compliance.

Supervisory Authority & Complaints

Under the General Data Protection Regulation (GDPR), individuals located in the European Union have the right to lodge a complaint with a competent data protection supervisory authority if they believe that the processing of their personal data infringes applicable data protection law.

EU users may submit a complaint to the supervisory authority in the Member State of their habitual residence, place of work, or the location of the alleged infringement. These authorities are responsible for monitoring compliance with the GDPR and safeguarding individual data protection rights.

DolRise encourages users to contact us directly in the first instance if they have questions, concerns, or complaints about how personal data is processed. We believe that many issues can be addressed efficiently through direct communication.

Submitting a complaint to a supervisory authority does not limit or affect a user’s right to pursue other legal remedies. DolRise does not retaliate against users for exercising their rights under the GDPR.

DolRise cooperates with supervisory authorities as required by law and responds to lawful inquiries, investigations, or enforcement actions in accordance with applicable data protection requirements.

This section is intended to inform EU users of their rights and the available mechanisms for raising concerns regarding data protection and privacy practices.

EU Contact Information

DolRise is committed to transparency and accountability in how personal data is handled under the General Data Protection Regulation (GDPR). Users located in the European Union may contact DolRise with questions, concerns, or requests related to data protection and privacy.

EU users may contact DolRise regarding the exercise of their rights under the GDPR, including requests for access, rectification, erasure, restriction of processing, or other privacy-related inquiries.

At this time, DolRise has not appointed a dedicated legal representative within the European Union. However, DolRise maintains a centralized point of contact for GDPR-related matters and handles such requests in accordance with applicable legal requirements.

Privacy-related inquiries from EU users may be directed to the following email address:

Email: [email protected]

DolRise aims to respond to valid requests within a reasonable timeframe and in accordance with GDPR obligations. If a legal representative is appointed within the EU in the future, this section will be updated accordingly.