Effective as of February 13, 2019

1. INTRODUCTION

We collect, use, process and share personal data in accordance with privacy laws to make sure your data protection rights are implemented and enforced. We integrate various technical and organizational solutions to comply with applicable laws and rules related to personal data protection in countries where we operate. This Privacy Policy sets forth the basic rules and principles by which we process your personal data, and mentions our responsibilities while processing personal data.

We may be a data processor or data controller according to the applicable law. Regardless of our status, we will deal with any personal data as required by any applicable regulation, including but not limited to, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”).

We do not knowingly attempt to solicit or receive information from children. Our services do not aim at children. The concrete age of the children are defined differently, so any case involving a child will be reviewed individually.

We understand that you are aware of and care about your own privacy interests, and we take that seriously. This Privacy Policy describes the rules and practices with regard to the collection and use of your personal data and details your privacy rights. We recognize that privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy and security rules.

 

2. TERMS WE USE AS LEGAL GUIDELINES OF THE PROCESSING

There are some legal bases for the processing of your personal data and we count on them to process your personal data. We use the main three bases to process your personal data: consent, contract, and legitimate interest.

Consent - your clear agreement to the processing of your personal data for a specific purpose.

Contract - the reason why the processing is necessary based on a contract you have with us, or because we have asked you to take specific steps before entering into that contract.

Legitimate Interests - the reason why the processing your data is necessary which is based on the legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests.

Articles 6(1) and 9(2) of the GDPR also indicate other legal grounds for the processing and when applicable we will count on such grounds.

 

3. CONSENT RULE AND INTERRELATION WITH OTHER LEGAL GROUNDS

If you have given consent to the processing of your data you can freely withdraw such consent at any time by contacting us.

If you do withdraw your consent, and if we do not have another legal basis for the processing of your data, then we will stop the processing of the personal data.

If we have another legal basis for the processing of your data, then we may continue to do so, subject to your legal interests and rights.

 

4. OUR RESPONSIBILITIES

As we may have both roles as a data controller and data processor, we have obligations according to the GDPR. We act as a data controller when we determine the purposes and means of the processing of your personal data. As a data processor, we process personal data on behalf of the controller.

 

5. RECOMMENDATIONS FOR YOU

You should read this Privacy Policy carefully. We want to make sure that you understand all your rights. It is important for both of us that you maintain your personal data confidential and secure.

If you provide us with personal data about other individuals, we will only employ that data for the special reason for which it was provided to us. By sending the data, you shall be sure that you have the right to dispose to process the personal data on your behalf in accordance with this Privacy Policy. In case if you submit the third party’s personal data, be sure that you have a legal basis for the processing of such data.

According to the applicable law, you may become a data controller/processor and it will impose on you additional obligations.

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6. PROCESSED DATA

We process personal data when you interact with our website https://dail.app (the “Website”) or any related Apple Store or Google Play applications (the “Applications”; the Website and Applications mean the “Platform”).

We would like to inform you that we interact with you and may process your personal data when:

- you browse any page of the Platform;

- you register;

- you log in;

- you communicate with us or other users;

- you use our services;

- you receive notification from us;

- we measure Platform traffic;

- in cases which do not depend on you but we have a legal basis to collect such data (see articles 6 and 9 of the GDPR).

We collect the following types of data:

- Personal data already collected by Google (name, email, image, etc.);

- your location;

- data that identifies you such as your IP address, login information, browser type, and version, time zone setting, browser plug-in types, some location information about where you might be, operating system and version;

- data on how you use the Platform such as your URL clickstreams (the path you take through the Platform), page response times, download errors, how long you stay on web pages, what you do on those pages, how often, and other actions;

- other personal data you share with us or personal data which we may legally obtain for our legitimate interests.

The recipients of the collected data are the highest management level of our company.

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7. PURPOSES AND LEGAL BASIS FOR THE PROCESSING

We process the data for:

- Registering users. We need your personal data to register you and identify each time you access the Platform or use our services. Legal basis: Consent; Legitimate Interests.

- Providing services. We need to provide services accessible via the Platform. Legal basis: Consent; Legitimate Interests.

- Providing offers and advertisement which may be interesting to you. Legal basis: Consent; Legitimate Interests.

- Informing you about our services or news (for example, you may receive our newsletters). Legal basis: Consent; Legitimate Interests.

- Keeping the Platform running (managing your requests, login, and authentication, remembering your settings, processing payments, hosting and back-end infrastructure). Legal basis: legitimate Interests.

- Preventing frauds, illegal activity or any violation of the terms or Privacy Policy. We may disable access to the Platform in some cases. Legal basis: legitimate Interests.

- Improving the Platform (testing features, interacting with feedback platforms, managing landing pages, heat mapping the Platform, traffic optimization, and data analysis and research, including profiling and the use of machine learning and other techniques over your data and in some cases using third parties to do this). Legal basis: Contract; legitimate Interests.

- Customer support (notifying you of any changes to the Platform, services, solving issues, any bug fixing). Legal basis: Contract; Legitimate Interests.

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8. YOUR RIGHTS AS DATA SUBJECT

You may ask us to refrain from using your data for marketing (when applicable). You can opt-out from marketing by contacting via the contact form.

You can exercise the following rights by sending us by contacting via the contact form.

You have the right to access information about you, especially:

- the categories of data;

- the purposes of data processing;

- third parties to whom the data disclosed;

- how long the data will be retained and the criteria used to determine that period;

- other rights regarding the use of your data.

You have the right to make us correct any inaccurate personal data about you.

You can object to using your personal data for profiling you or making automated decisions about you. We may use your data to determine whether we should let you know information that might be relevant to you (for example, tailoring emails to you based on your behavior).

You have the right to the data portability of your data to another service or website. We will give you a copy of your data in a readable format so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the data to the other service for you.

You have the right to be “forgotten”. You may ask erasing any personal data about you if it is no longer necessary for us to store the data for purposes of your use of the Platform.

You have the right to lodge a complaint regarding the use of your data by us. You can address any complaint to your national regulator (see the list at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm).

In the context of the right to access information, we shall provide you with the information within one month of your request unless there is a justified requirement to provide such information faster. This term may be prolonged according to the GDPR and applicable law.

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9. AUTOMATIC DECISION MAKING AND SPECIAL CATEGORIES OF PERSONAL DATA

We use automated decision making and/or profiling in regards to your personal data for some services and products, for example for disabling prohibited content as described in our Terms.

We do not intentionally use special categories of data, such as your photo but your photo may reveal your social or ethnic origin, religious or philosophical beliefs, or data concerning health. Nevertheless, we do not collect your photos to define your social or ethnic origin, religious or philosophical beliefs, or data concerning health but rather to define your identification or whether your photo satisfies our Terms, community standards or applicable law.

You can request a manual review of the accuracy of an automated decision that you are unhappy with or limit or object to such automated decision making and/or profiling by contacting us at.

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10. SECURITY

We have security and organizational measures and procedures to secure the data collected and stored. You acknowledge that no data transmission is guaranteed to be 100% secure and there may be risks. You are responsible for your login information and password. You shall keep them confidential. In case if your privacy has been breached, please contact us immediately.

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11. LOCATION OF THE PROCESSING OF PERSONAL DATA AND THIRD PARTY SERVICE PROVIDERS

The personal data is collected by our company incorporated in Saudi Arabia but we use Amazon Web Services which provides on-demand cloud computing platforms so your personal data is stored in the European Economic Area.

The Platform contains links to third party sites and features. The Privacy Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their sites, features or policies. Please read their privacy policies before you submit any data to them. There are the following third parties.

- the Website is built on the Wix platform (web development company);

- third-party advertisements when you visit and use the Platform such as Google AdMob. This may collect and use clickstream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Platform and other websites in order to provide advertisements about goods and services likely to be of interest to you. It typically uses tracking technologies to collect this information. The use of tracking technologies is subject to the third party’s own privacy policies;

- we use Amazon analytics to analyze data, advertise and improve our services and Platform;

- Amazon Web Services provides on-demand cloud computing platforms;

- we use social media sources such as Twitter and Instagram.

12. RETENTION POLICY

We store personal data as long as we need it and the retention practice depends on the type of data we collect, regulatory burden, and how we use the personal data. The retention period is based on criteria that include legally mandated retention periods, pending or potential litigation, intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving.

Some national laws require us to store some metadata. For example, such data may include: tracing and identification of the source of communication; identification of the destination of communication; identification of the date, time and duration of communication; identification of the type of communications service; identification of the terminal equipment or presumable terminal equipment of a user of communications services; determining of the location of the terminal equipment.

Additionally, we may be a provider of Internet access or Internet telephony services which require us to collect and store for some period of time (for example, some countries, mainly, mention 1 (one) year and 2 (two) years upon a request of authorities) the following (when applicable):

- the user IDs allocated by us;

- the name and address of the subscriber to whom an Internet Protocol (IP) address, user ID or telephone number was allocated at the time of the communication;

- the user ID or telephone number of the intended recipient of an Internet telephony call;

- the name, address and user ID of the subscriber who is the intended recipient in the case of the Internet telephony services;

- the date and time of beginning and end of the Internet session, based on a given time zone, together with the IP address allocated to the user by the Internet service provider and the user ID;

- the date and time of the log-in and log-off of the Internet telephony service, based on a given time zone;

- the Internet service used in the case of Internet telephony services;

- the number of the caller in the case of dial-up Internet access;

- the digital subscriber line (DSL) or another end point of the originator of the communication.

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13. COOKIE POLICY

We collect certain types of information when you access or use the Platform, including cookies and similar tracking technologies.

Cookies are small data files that are placed on your computer or mobile device when you visit the Platform. Cookies are used by the Platform in order to make the Platform work, or to work more efficiently, as well as to provide reporting information.

You may turn off cookies in your browser via settings. You can block cookies on your browser refusing cookies. You may delete cookies. If you turn off cookies, you can continue to use the Platform and browse its pages, but the Platform and certain services will not work properly.

The list of cookies we use is listed in your browser or there is a list of types of such cookies.

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