Donaki Members Privacy Policy

Last updated:April 20, 2026

1. Introduction

This Privacy Policy explains how Donaki Members collects, uses, stores, protects, and, where applicable, transfers the personal data of individuals who use the Donaki Members platform (hereinafter the “Platform”).

Donaki Members attaches particular importance to the protection of privacy and is committed to processing personal data in accordance with applicable law, and in particular Regulation (EU) 2016/679 (“GDPR”) as well as applicable Belgian legislation.

2. Data Controller

The data controller for personal data processed within the framework of Donaki Members is:

Scorpius XI srl
Company Number (BCE): BE0652760906
VAT Number: BE0652760906
Email: support@donaki.com
Contact Page: https://members.donaki.com/contact-admin

3. Data Protection Officer / Privacy Contact

For any questions relating to the protection of personal data, you can contact:

privacy@donaki.com

This email address is the privacy contact point.

4. Personal Data Collected

4.1 Minimum Data Required to Use the Service

• email address;
• encrypted password;
• username;
• first and last name;
• date of birth;
• avatar;
• at least one item from a partner store;
• at least one connection/friendship with another member.

The first and last name can be freely entered by the user. Donaki Members encourages the use of a real first and last name, although this is not a general requirement, except when certain features or procedures require it. The date of birth provided by the user is considered accurate. 4.2 Optional Data Address; 4.3 Data Collected for Verified Profiles When a user requests a verification badge, Donaki Members may optionally collect a photograph of an identity document to verify the match between the first and last name and, if applicable, the profile picture. This identity document is stored in a secure directory and is used only for the verification process. It is deleted as soon as the badge request is accepted or rejected. This feature aims to enhance the perceived reliability of profiles for other members. 4.4 Data Resulting from the Use of the Platform Links between friends, created or deleted by the user; Notifications related to the user's actions or inactions on the Platform; Messages exchanged via the internal messaging system; Content published by the user; Technical logs and security data strictly necessary for the operation, protection, and administration of the Platform; 5. Purposes of Processing

Personal data is processed for the following purposes:

• to enable the creation and management of the user account;
• to authenticate members and secure access to the Platform;
• to display and manage the user profile;
• to enable community interactions between members;
• to manage friendship relationships between members;
• to provide internal messaging between authorized members;
• to manage notifications related to the use of the Platform;
• to enable the optional profile verification procedure;
• to ensure the maintenance, security, abuse prevention, malfunction detection, and protection of the Platform;
• to respond to user support requests and questions;
• to comply with applicable legal obligations ;

6. Legal Basis for Processing

Depending on the circumstances, Donaki Members processes personal data on the following legal bases:

• the performance of services provided to the user via the Platform;
• Donaki Members' legitimate interest in ensuring the proper functioning, security, moderation, abuse prevention, and technical improvement of the Platform;
• compliance with a legal obligation;
• the user's consent, when required for a particular feature;

7. Profile Data and Visibility Settings

The user profile can contain several pieces of information visible to other members of the Platform.

The user can choose to hide the following data on their profile page as seen by other users:

• First name;
• Last name;
• Date of birth;
• Address.

The username is the primary identifier for the profile and cannot be hidden.

Visibility settings - default values ​​if entered:

First name - Everyone
Last name - Everyone
Date of birth - All members
Address - Only my friends City - All members Postal code - All members Country - Everyone

8. Publicly Visible Data

The Activity page of Donaki Members is publicly visible.

The following may appear on it:

• Profile picture changes;
• Messages left on this page by verified members;

Donaki Members may also publish the total number of its members, without naming individual members.

9. Internal Messaging

Donaki Members provides its members with an internal messaging system.

Only members connected by a friendship relationship may contact each other via this messaging system, subject to the Platform's operating rules.

Messages are processed to enable internal communication, ensure the Platform's security, handle reports, and comply with legal obligations when required.

10. Data Recipients

Personal data may be accessible, to the extent necessary, to the following categories:

• Donaki Members' internal teams responsible for administration, support, security, moderation, and maintenance;
• Other members, to the extent permitted by profile settings and the Platform's operation;
• Technical service providers involved in hosting, infrastructure, maintenance, security, backups, or email delivery;
• Competent authorities when required by law;

Donaki Members does not use advertising or analytics cookies and does not sell personal data to third parties.

11. Cookies

Donaki Members only uses cookies and similar technologies that are strictly necessary for the technical operation of the Platform, authentication, security, session maintenance, and the proper provision of the service requested by the user.

No audience measurement, behavioral advertising, or marketing tracking cookies are placed within the framework described in this policy, unless otherwise stated in a separate policy or after explicit updates to the information provided to users.

12. Transfers outside the European Economic Area

The Platform is usable worldwide.

Donaki Members' main server is hosted in the United States.

Mirror servers or additional technical infrastructure may also be distributed across other countries to improve speed, availability, and user experience. Consequently, some personal data may be transferred to or hosted outside the European Economic Area. 13. Data Retention Period

Personal data is retained as long as the user account is active.

If the account is deleted by the member, the personal data is anonymized.

However, certain data may be retained for longer periods when strictly necessary to:

• comply with a legal obligation;
• ensure the security of the Platform;
• prevent or address abuse;
• manage a dispute;
• maintain temporary technical backups;

Documents voluntarily submitted by a member as part of a profile verification request to obtain the "verified" badge next to their username are deleted as soon as the request is accepted or rejected.

14. Security

Donaki Members implements reasonable technical and organizational measures designed to protect personal data against loss, unauthorized access, alteration, disclosure, or unlawful destruction.

The user's password is stored in encrypted/hashed form.

The directory used to temporarily store provided identity documents is protected.

15. User Rights

In accordance with applicable law, you may, in particular, request:

• access to your personal data;
• rectification of inaccurate data;
• erasure of your data in cases provided for by law;
• restriction of certain processing;
• objection to certain processing, where permitted by law;
• data portability, where applicable.

Account deletion is available.

For any questions or to exercise your rights, you can contact: support@donaki.com or privacy@donaki.com.

16. Minors

The Platform is accessible to minors.

Each user is advised to ensure that they are authorized, under the laws applicable to them, to register for and use a social network or online service such as Donaki Members.

Where applicable law requires parental authorization or specific conditions for certain processes involving minors, these rules must be respected.

17. Complaints

If you believe that the processing of your personal data does not comply with applicable legislation, please contact us first at privacy@donaki.com or support@donaki.com.

You also have the right to lodge a complaint with the competent Data Protection Authority in Belgium:

Data Protection Authority
Rue de la Presse 35, 1000 Brussels


18. Changes to this Policy

Donaki Members may modify this Privacy Policy to reflect, in particular, legal, regulatory, technical, or functional changes to the Platform.

The applicable version is the one published on the Platform with its last update date.

In the event of a substantial change, Donaki Members may inform users by any appropriate means.

19. Contact

For any questions regarding this Privacy Policy, you can contact:

Scorpius XI srl
https://members.donaki.com/contact-admin
support@donaki.com
privacy@donaki.com