Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

■ names

■ phone numbers

■ email addresses

■ mailing addresses

■ job titles

■ contact preferences

■ billing addresses

■ debit/credit card numbers

■ contact or authentication data

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

■ financial data

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Zoho. You may find their Privacy Policy here: https://www.zoho.com/privacy.html

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In short: Some information – such as your Internet Protocol (IP) address and/or browser and device characteristics—is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

■ Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).

■ Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

■ Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

In short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

■ To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

■ To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

■ To send administrative information to you. We may process your information to send you details about our products and Services, changes to our terms and policies, and other similar information.

■ To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

■ To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

■ To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

■ To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see ‘WHAT ARE YOUR PRIVACY RIGHTS?’ below.

■ To deliver targeted advertising to you. We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more.

■ To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

■ To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

■ Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

■ Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

■ Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

■ Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

■ Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

■ If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

■ For investigations and fraud detection and prevention

■ For business transactions provided certain conditions are met

■ If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

■ For identifying injured, ill, or deceased persons and communicating with next of kin

■ If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

■ If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

■ If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

■ If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

■ If the collection is solely for journalistic, artistic, or literary purposes

■ If the information is publicly available and is specified by the regulations

■ We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

We may need to share your personal information in the following situations:

■ Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

■ When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API). Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location. GPS is accurate to about 20 meters, while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, like indoors. This data helps Google Maps provide directions, but it is not always perfectly precise.

■ Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

■ Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a ‘sale’/’sharing’ (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section ‘DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?’

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services.

The Google Analytics Advertising Features that we may use include:

■ Google Analytics Demographics and Interests Reporting

■ Google Display Network Impressions Reporting

To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice

For more information on the privacy practices of Google, please visit https://policies.google.com/privacy

Our servers are located in the United Arab Emirates. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see ‘WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?’ above), including facilities in the United Arab Emirates, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at privacy@rdvmedia.ae

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’ below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’ below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you; for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at privacy@rdvmedia.ae

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

Categories of Personal Information We Collect

The table below shows the categories of personal information we may collect. The table includes illustrative examples of each category and may not reflect the specific personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section “WHAT INFORMATION DO WE COLLECT?’

CATEGORY	EXAMPLES
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data
D. Commercial information	Transaction information, purchase history, financial details, and payment information
E. Biometric information	Fingerprints and voiceprints
F. Internet or other similar network activity	Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements
G. Geolocation data	Device location
H. Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities
I. Professional or employment-related information	Business contact details in order to provide you with our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
J. Education Information	Student records and directory information
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
L. Sensitive personal Information	Debit or credit card numbers

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the sole purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

■ Receiving help through our customer support channels;

■ Participation in customer surveys or contests; and

■ Facilitation in the delivery of our Services and to respond to your inquiries.

We may use and retain the collected personal information as needed to provide the Services or for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Learn more about the sources of personal information we collect in ‘WHAT INFORMATION DO WE COLLECT?’

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, ‘HOW DO WE PROCESS YOUR INFORMATION?’

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, ‘WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?’

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be ‘selling’ of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

■ Right to know whether or not we are processing your personal data

■ Right to access your personal data

■ Right to correct inaccuracies in your personal data

■ Right to request the deletion of your personal data

■ Right to obtain a copy of the personal data you previously shared with us

■ Right to non-discrimination for exercising your rights

■ Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (‘profiling’)

Depending upon the state where you live, you may also have the following rights:

■ Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)

■ Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)

■ Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)

■ Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)

■ Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)

■ Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)

■ Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at privacy@rdvmedia.ae, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@rdvmedia.ae. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California ‘Shine The Light’ Law

California Civil Code Section 1798.83, also known as the ‘Shine The Light law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated ‘Last updated’ date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

RDV Media LLC

P.O. BOX 3860

Sharjah

United Arab Emirates

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please submit a data subject access request via email at privacy@rdvmedia.ae.