Privacy Policy

1.1We are committed to safeguarding the privacy of our application visitors; in this policy we explain how we will treat your personal information.
1.2[We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our application. / By using our application and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.]
2.Collecting personal information
2.1We may collect, store and use the following kinds of personal information:
(a)[information about your computer and about your visits to and use of this application (including [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and application navigation paths]);]
(b)[information that you provide to us when registering with our application (including [your email address]);]
(c)[information that you provide to us when registering with our application (including [your email address]);]
(d)[information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including [your name and email address]);]
(e)[information that you provide to us when using the services on our application, or that is generated in the course of the use of those services (including [the timing, frequency and pattern of service use]);]
(f)[information relating to any purchases you make of our [goods / services / goods and/or services] or any other transactions that you enter into through our application (including [your name, address, telephone number, email address and card details]);]
(g)[information that you post to our application for publication on the internet (including [your user name, your profile pictures and the content of your posts]);]
(h)[information contained in or relating to any communication that you send to us or send through our application (including [the communication content and metadata associated with the communication]);]
(i)[any other personal information that you choose to send to us; and]
(j)[[provide details of other personal information collected].]
2.2Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.
3.Using personal information
3.1Personal information submitted to us through our application will be used for the purposes specified in this policy or on the relevant pages of the application.
3.2We may use your personal information to:
(a)[administer our application and business;]
(b)[personalise our application for you;]
(c)[enable your use of the services available on our application;]
(d)[send you goods purchased through our application;]
(e)[supply to you services purchased through our application;]
(f)[send statements, invoices and payment reminders to you, and collect payments from you;]
(g)[send you non-marketing commercial communications;]
(h)[send you email notifications that you have specifically requested;]
(i)[send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);]
(j)[send you marketing communications relating to our business [or the businesses of carefully-selected third parties] which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);]
(k)[provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);]
(l)[deal with enquiries and complaints made by or about you relating to our application;]
(m)[keep our application secure and prevent fraud;]
(n)[verify compliance with the terms and conditions governing the use of our application [(including monitoring private messages sent through our application private messaging service)]; and]
3.3If you submit personal information for publication on our application, we will publish and otherwise use that information in accordance with the licence you grant to us.
3.4Your privacy settings can be used to limit the publication of your information on our application, and can be adjusted using privacy controls on the application.
3.5We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.
3.6All our application financial transactions are handled through our payment services provider, [PSP name]. You can review the provider's privacy policy at [URL]. We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our application, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.Disclosing personal information
4.1We may disclose your personal information to [any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors] insofar as reasonably necessary for the purposes set out in this policy.
4.2We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.3We may disclose your personal information:
(a)to the extent that we are required to do so by law;
(b)in connection with any ongoing or prospective legal proceedings;
(c)in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d)[to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and]
(e)Access or otherwise interact with our application using any robot, spider[ah] or other automated means.
4.4Except as provided in this policy, we will not provide your personal information to third parties.
5.International data transfers
5.1Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
5.2Personal information that you publish on our application or submit for publication on our application may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
5.3You expressly agree to the transfers of personal information described in this Section 6.
6.Retaining personal information
6.1This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3Without prejudice to Section 7.2, we will usually delete personal data falling within the categories set out below at the date/time set out below: (a) [All types of personal data] will be deleted [5 years; and]
6.4Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data:
(a)to the extent that we are required to do so by law;
(b)if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c)in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7.Security of personal information
7.1We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
7.3All electronic financial transactions entered into through our application will be protected by encryption technology.
7.4You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.5You are responsible for keeping the password you use for accessing our application confidential; we will not ask you for your password (except when you log in to our application).
8.1We may update this policy from time to time by publishing a new version on our application.
8.2You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3We may notify you of changes to this policy [by email or through the private messaging system on our application].
9.Your rights
9.1You may instruct us to provide you with any personal information we hold about you.
9.2We may withhold personal information that you request to the extent permitted by law.
9.3You may instruct us at any time not to process your personal information for marketing purposes.
9.4In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
10.Third party applications
10.1WOur application includes hyperlinks to, and details of, third party applications.
10.2We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11.Updating information
11.1Please let us know if the personal information that we hold about you needs to be corrected or updated.
12.1Our application uses cookies.
12.2A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a application server to a application browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
12.3Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a application browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the application browser is closed.
12.4Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12.5We use [only session cookies / only persistent cookies / both session and persistent cookies] on our application.
12.6The names of the cookies that we use on our application, and the purposes for which they are used, are set out below:
(a)we use [cookies] on our application to [recognise a computer when a user visits the application / track users as they navigate the application / enable the use of a shopping cart on the application / improve the application's usability / analyse the use of the application / administer the application / prevent fraud and improve the security of the application / personalise the application for each user / target advertisements which may be of particular interest to specific users /
12.7Most browsers allow you to refuse to accept cookies.
12.8Blocking all cookies will have a negative impact upon the usability of many applications.
12.9If you block cookies, you will not be able to use all the features on our application.
12.10You can delete cookies already stored on your computer.
12.11Deleting cookies will have a negative impact on the usability of many applications.
13.Our details
13.1This application is owned and operated by Shighel projects Managements.
13.2We are registered in [Kuwait] under registration number [.......], and our registered office is at [_______].
13.3You can contact us by writing to the business address given above, by using our application contact form, by email to [_________] or by telephone on [________].