These periods represent the Owner’s internal policy standards and may be updated from time to time to reflect legal, regulatory, or operational changes.

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5. The Purposes of Processing

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The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Managing contacts and sending messages, Hosting and backend infrastructure, Platform services and hosting, Contacting the User, Advertising, Analytics, Displaying content from external platforms, User database management, Handling payments, Location-based interactions and Tag Management.

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For specific information about the Personal Data used for each purpose, the User may refer to the section "Detailed Information on the Processing of Personal Data".

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For technical or operational reasons, deletion of Personal Data may not be immediate and may require up to 90 days to be fully completed across all systems, including backups.

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The Owner may continue to store and use aggregated or anonymised information, which does not identify Users, for the purposes of improving the Platform, enhancing algorithms, maintaining security, and developing new services.

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6. Detailed Information on the Processing of Personal Data

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Personal Data is collected for the following purposes and using the following services:

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 1. Analytics

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 The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

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 Google Analytics (Google LLC)

 Google Analytics is a web analysis service provided by Google LLC ("Google"). Google utilises the Data collected to track and examine the use of This Platform, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

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Personal Data processed: Cookies; Usage Data.

Place of processing: United States –  Privacy Policy- Opt-Out. Privacy Shield participant.

Category of personal data collected according to CCPA: internet information.

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This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

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Google Analytics Advertising Reporting Features (Google LLC)

Google Analytics on This Platform has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (Website activity). It allows the Owner to analyse specific behaviour and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

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Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

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Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the          privacy policy of the service. Place of processing: United States – Privacy Policy– Opt-Out. Privacy Shield participant. Category of personal data collected according to CCPA: identifiers; internet information.

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This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

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2. Handling Payments

   

Unless otherwise specified, This Platform processes any payments by debit or credit card or other means via external payment service providers. In general, and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Platform is not involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed

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Stripe Inc.

Place of processing: United States – Privacy Policy

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Apple Inc.

Place of processing: United States – Privacy Policy

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3. Hosting and Backend Infrastructure

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This type of service has the purpose of hosting Data and files that enable This Platform to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of This Platform

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Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored..

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Amazon Web Services (AWS) (Amazon Web Services, Inc.)

Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

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Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: India and USA –  Privacy Policy Privacy Shield participant.

Category of personal data collected according to CCPA: internet information.

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4. Location-Based Interactions

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Non-continuous geolocation (This Platform)

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This Platform may collect, use, and share User location Data in order to provide location-based services.

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 Most browsers and devices provide tools to opt out from this feature by default. If explicit authorisation has been provided, the User's location data may be tracked by This Platform.

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The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate f ield and allows the application to detect the position automatically.

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Personal Data processed: geographic position.

Category of personal data collected according to CCPA: geolocation data.

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5. Managing Contacts and Sending Messages

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This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

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These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

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Firebase Authentication (Google LLC)

Firebase Authentication is a user identity and authentication service provided by Google LLC. It is used for email storage and authentication.

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Personal Data processed: email address.

Place of processing: United States – Privacy Policy

Category of personal data collected according to CCPA: identifiers.

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This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

       

Firebase Cloud Messaging (Google LLC)

Firebase Cloud Messaging is a message delivery service provided by Google LLC. It is used for handling email-related services and communication.

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Personal Data processed: email address, usage data.

Place of processing: United States – Privacy Policy

Category of personal data collected according to CCPA: identifiers.

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This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

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SendGrid (Twilio Inc.)

SendGrid is an email delivery and push notification service provided by Twilio Inc.

   

Personal Data processed: email address, usage data.

Place of processing: United States – Privacy Policy 

Category of personal data collected according to CCPA: identifiers.

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This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

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6. Platform Services and Hosting

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These services have the purpose of hosting and running key components of This Platform, therefore allowing the provision of This Platform from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e commerce, payment processing – that imply the collection and handling of Personal Data.

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Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

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Apple App Store (Apple Inc.)

This Platform is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

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By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of This Platform. Much of this information is processed on an opt-in basis.

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Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

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Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy Privacy Shield participant.

Category of personal data collected according to CCPA: internet information.

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This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

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Google Play Store (Google LLC)

This Platform is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC.

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By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis. Users may opt-out of this analytics feature directly through their device settings. More information on how to   manage analysis settings can be found on this page.

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Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy Privacy Shield participant.

Category of personal data collected according to CCPA: internet information.

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This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

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7. Tag Management

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This type of service helps the Owner to manage the tags or scripts needed on This Platform in a centralised fashion. This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

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Tealium IQ Tag Management (Tealium Inc.)

Tealium IQ tag Management is a tag management service provided by Tealium Inc.

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Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy Privacy Shield participant.

Category of personal data collected according to CCPA: internet information.

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This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

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8. User database management

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This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to This Platform, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving This Platform.

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Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on This Platform.

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Microsoft Cloud Services

Personal Data: address; country; email address; first name; last name; phone number – Privacy Policy

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7. Further Information About Personal Data

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1. Push Notifications

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This Platform may send push notifications to the User to achieve the purposes outlined in this Privacy Policy

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Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for This Platform, some or all of the apps on the particular device.

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Users must be aware that disabling push notifications will negatively affect the utility of This Platform.

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2. Selling goods and services online

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The Personal Data collected are used to provide the User with services or to sell goods, including payment.

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The Personal Data collected to complete the payment may include the debit or credit card, or any other means of payment envisaged. The kind of Data collected by This Platform depends on the payment system used.

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8. The Rights of Users

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1. Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:

a. Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data..

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b. Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

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c. Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.

 

d. Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

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e. Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

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f. Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

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g. Users have the right to obtain a copy of their Personal Data in a structured, commonly used, and machine-readable format. Users may also request that such data be transmitted directly to another controller whenever technically feasible. This right applies regardless of the legal basis for processing, including when the data is processed based on consent, contractual necessity, or any other lawful basis under Bahraini law. The Owner will take reasonable steps to facilitate the portability of personal data while ensuring the security and confidentiality of the data during transfer. This right does not require the Owner to create or generate new data or metadata, and the exercise of this right is subject to applicable limitations under Bahraini law to protect the rights and freedoms of other individuals or to comply with legal obligations.

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h. Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

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2. Details About the Right to Object to Processing

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Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

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Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of  this document.

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3. How to Exercise These Rights

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Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible.

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9. Cookie Policy

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This Platform uses Cookies and other Identifiers. To learn more, the User may consult the Cookies Policy.

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10. Additional Information about Data Collection and Processing

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1. Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of This Platform or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

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2. Additional Information about User's Personal Data

In addition to the information contained in this Privacy Policy, This Platform may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

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3. System Logs and Maintenance

For operation and maintenance purposes, This Platform and any third-party services may collect files that record interaction with This Platform (System logs) use other Personal Data (such as the IP Address) for this purpose.

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4. Information Not Contained in this Privacy Policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

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5. How "Do Not Track" Requests are Handled

This Platform does not support "Do Not Track" requests.

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To determine whether any of the third-party services it uses honour the "Do Not Track" requests, please read their privacy policies.

       

6. Changes to this Privacy Policy

The Owner reserves the right to make changes to this Privacy Policy at any time by notifying its Users on this page and possibly within This Platform and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User's consent, the Owner shall collect new consent from the User, where required.

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11. Information for Californian Consumers

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This part of the document integrates with and supplements the information contained in the rest of the Privacy Policy and is provided by the business running This Platform and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as "we", "us", "our").

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The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as "you", "your", "yours"), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the Privacy Policy.

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This part of the document uses the term "personal information" as it is defined in The California Consumer Privacy Act ("CCPA").

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1. Categories of Personal Information Collected, Disclosed or Sold

In this section we summarise the categories of personal information that we have collected, disclosed, or sold and the purposes thereof. You can read about  these activities in detail in the section titled "Detailed information on the processing of Personal Data" within this document.

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a.Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, internet information and geolocation data. We will not collect additional categories of personal information without notifying you.

    

b. How we collect information: what are the sources of the personal information we collect?

We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use This Platform.

      

For example, you directly provide your personal information when you submit requests via any forms on This Platform. You also provide personal information  indirectly when you navigate This Platform, as personal information about you is automatically observed and collected. Finally, we may collect your personal  information from third parties that work with us in connection with the Service or with the functioning of This Platform and features thereof.

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c. How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

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We may also disclose your personal information to third parties when you explicitly ask or authorise us to do so, in order to provide you with our Service. To find out more about the purposes of processing, please refer to the relevant section of this document.

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d. Sale of your personal information

For our purposes, the word "sale" means any "selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration".

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses  tools such as social network plugins and the like.

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e. Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.

Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

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f. Instructions to opt out of the sale of personal information

If you'd like to know more, or exercise your right to opt out in regard to all the sales carried out by This Platform, both online and offline, you can contact us for  further information using the contact details provided in this document.

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g. What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of This Platform and features thereof ("business purposes"). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

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We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section "Detailed information on the processing of Personal Data" within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

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We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

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2. Your California Privacy Rights and How To Exercise Them

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a. The right to know and to portability

You have the right to request that we disclose to you:

i. the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;

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ii.in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:

1.for sales, the personal information categories purchased by each category of recipient; and

2. for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

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iii.The disclosure described above will be limited to the personal information collected or used over the past 12 months.

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If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

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b. The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on This Platform, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

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If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

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c. How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

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For us to respond to your request, it is necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

        

i. provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorised representative;

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ii. describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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d. We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorise a person registered with the California Secretary of State to act on your behalf. If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

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You can submit a maximum number of 2 requests over a period of 12 months.

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e. How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

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We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfil your request.

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Our disclosure(s) will cover the preceding 12-month period.

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Should we deny your request, we will explain you the reasons behind our denial.

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We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it. it.

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12. Data Portability Clause

The user has the right to request their data in a machine-readable format. You may also request your data to be transferred to another data controller. Whether feasible or necessary.

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13. Governing Law and Dispute Resolution

This Privacy Policy is governed by, and shall be construed in accordance with, the laws of the Kingdom of Bahrain. We may, where appropriate, align Our practices with recognised international standards (including principles found in the GDPR) to enhance transparency and User rights; such alignment does not constitute submission to any non-Bahraini jurisdiction. In the event of any inconsistency, the laws of the Kingdom of Bahrain shall prevail.

Any dispute arising out of or in connection with this Privacy Policy (including any question regarding its existence, validity, interpretation, performance, or termination) shall be referred to and finally resolved by arbitration administered by the Bahrain Chamber for Dispute Resolution (BCDR) in accordance with the Rules of Arbitration of the Bahrain Chamber for Dispute Resolution of 2022. The seat of arbitration shall be the Kingdom of Bahrain. The arbitral tribunal shall consist of three arbitrators, as determined in accordance with Article 8 of the BCDR Arbitration Rules. The language of the arbitration shall be English. The legislation that shall apply for the arbitration proceedings shall be Bahraini Law.

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