DALEELO COMMUNITY NETWORK PRIVACY POLICY

(Last Updated May 14, 2020)

1)     Introduction

Welcome to Daleelo Community Network and Daleelo.comWebsite.

This Privacy Policy iscreated so you know that all personal data collected by Daleelo CommunityNetwork and Daleelo.com are processed in accordance with the law on legalprotection of personal data and principles of the European Union GDPR dataprotection act 1998 and May 25, 2018. By accessing this site you agree to theterms of this privacy policy and consent to the collection, processing, use ortransfer of data as set out in this policy.

The following is generalinformation on Daleelo Community Network privacy practices. Please read ourprivacy statement and let us know if you have any questions.

1.     Overview

2.     Personal information we collect about you PIPEDA

3.     Types of data collected

4.     Sweepstakes and other promotion

5.     Online surveys

6.     How we collect your data

7.     Cookies and other technologies

8.     How we use your information.

9.     Transfer of Information to the United State Americaand Other Countries

10. California / Delaware Do Not Track Disclosures

11. Where we store your information

12. How we secure information we collect

13. Provision of Personal Data and failure to providePersonal Data

14. How long we keep information

15. Blogs, Reviews and Forums

16. Marketing information:

17. How to access and control your information

18. Consent to provide personal information

19. Transfer to third parties

20.  Your rights as a data subject

21. Privacy shield

22. Legal bases for processing (for EEA users):

23. Our COPPA policy towards children

24. How we protect your information

25. Residents of California

26. Your right to withdraw consent

27. Opting out

28. Data Privacy Regulatory Frameworks and Requirements

29. Data portability

30. About security and personal Information

31. Complaints to a data protection authority

32.  Contact us

33.  Privacy policy changes

Please read the following carefully to understandour views and practices regarding your personal data and how we will treat it. By using the platform you acknowledge you haveread and understood this privacy policy.

2)     Personal information we collect about you (PIPEDA)

According to the Canadianpersonal information protection and electronic documents act, 2000 (PIPEDA),“personal information” means information about an identifiable individual. Theinformation you provide to Daleelo Community Network is considered personalinformation it is possible to relate it back to you through your name, address,e-mail address, telephone number and any other information that can identifyyou.

If information cannot berelated to an identifiable individual it is considered anonymous information. Wheneverpossible, Daleelo Community Network works with anonymous information. Thisprivacy statement does not apply to anonymous information.

3)     Types of data we collect from you

Personally Identifiable Information (PII). "Personal Information" is informationabout an identifiable individual, such as your name, email address, telephonenumber, payment card information, date of birth, product/buying preferences. Wemaintain one or more databases to store your Personal Information and mayretain it as reasonably required to serve you and operate the Service. PersonalInformation that we collect depends on how you use the Service, includingcreating an online account with us, making a purchase or a return, contactingus via any customer service method, signing up to receive promotional emails orother communication, participating in customer research, surveys, contests orpromotions, or otherwise communicate information to us. Providing your PersonalInformation to us is your choice. If you choose not to provide us with certainPersonal Information, you may not be able to take advantage of certain featuresof the Service; and

Sensitive PII. In certain circumstances, such as when subscribing for our service, youmay provide a Government identifiers, such as national identification numbersand driver’s license numbers, credit, debit, or payment account number, orother payment information to our payment gateway provider which we recognize asmore sensitive than other PII.

Anonymous Data. Some of the Data that we acquire cannot identify, distinguish or traceyou or your Device, even if combined with other identifying information, andsome Data that could be considered PII when combined with other identifyinginformation is not used in a way that identifies, distinguishes or traces youor your Device, but is instead used in an anonymous way, often aggregated withother anonymous Data about other users.

4)     Sweepstakes and Other Promotions

From time to time, we mayoffer sweepstakes or other promotions on our website and platform. If you entera sweepstakes or promotional contest, we will ask you to provide informationabout yourself (such as your name, phone number, address, date of birth, andemail address). Among other things, we will use this information to contact youif you win, and we may also use this information for marketing purposes. We mayshare this information with any co-sponsor of the contest or sweepstakes; wewill identify the co-sponsor in the contest rules. If you do not want us tocollect the information requested in the contest or sweepstakes registrationform or to provide it to co-sponsors, please do not enter the contest orsweepstakes.

5)      Online Surveys

From time to time, wesurvey our users to measure their satisfaction with our website and platformand other sites and to help us learn more about our audience and how theyinteract with our website and platform. Third-party research firms oftenconduct these surveys on our behalf. We use the survey results to help usimprove the services we offer to you. We will take the information you provideand aggregate it on an anonymous basis with data collected from other surveyparticipants. We may use and disclose that pool of anonymous information as wesee fit, without identifying you personally.

6)     How we collect your data

When you access or useour website, we automatically collect information about you, including but notlimited to:

  • Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, your general location and the page you visited before navigating to our Services.
  • Transactional Information: When you make a purchase for a service, we collect information about the transaction, such as purchase details, purchase price, and date and location of the transaction. We or a designated third party may collect payment and credit card information when you subscribe to our paid Services or purchase additional services.
  • Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
  • Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see or visit our “Cookie Policy
  • Clickstream Data: As you use the Internet, a trail of electronic information is left at each website and platform you visit. This information, sometimes referred to as "Clickstream Data," can be collected and stored by a website and platform’s server. For example, Clickstream Data can tell the type of computer and browsing software you use and the address of the website and platform from which you linked to the website and platform. The Website and platform may collect and use Clickstream Data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our website and platform, how visitors navigate throughout the Website and platform and how we may tailor our website and platform to better meet the needs of visitors. This information often will be used to improve our Website and platform and our services. Any collection or use of clickstream data will be anonymous and aggregated and will not intentionally contain any Personal Information.

Be Careful Publicly Posting PII. Please be aware that Content and PII that youdisclose in publicly accessible portions of the Service may be available toother users, and may also be made available outside the Service by thirdparties, so you should be mindful of all PII, especially sensitive PII, thatyou may wish to post.

7)     Cookies and other technologies

Our platforms use cookiesand similar technologies to distinguish you from other users of our platforms.This helps us to provide you with a good experience when you browse ourplatform and also allows us to improve our services. Most browsersautomatically accept cookies and similar technologies, but if you prefer, youcan change your browser to prevent that and your help screen will tell you howto do this. We also give you information about disabling cookies. However, youmay not be able to take full advantage of our web site if you do so.

A number of cookies andsimilar technologies we use last only for the duration of your web or appsession and expire when you close your browser or exit the site. Others areused to remember you when you return to the platform and will last for longer.

We use these cookies andother technologies on the basis that they are necessary for the performance ofa contract with you, or because using them is in our legitimate interests(where we have considered that these are not overridden by your rights), and, insome cases, where required by law, where you have consented to their use.

8)     How we use your information

We use the information wecollect to provide, maintain and improve our Services, such as to administeryour account and to provide you with insights to help you optimize your use ofour platform.

We may also use theinformation we collect to:

  • Process and deliver the products you requested, process transactions and send you transaction-related information, including confirmations and invoices,
  • Send you technical notices, updates, security alerts and support and administrative messages;
  • Respond to your comments, questions and requests and provide customer service;
  • Communicate with you about products, services, offers, promotions, rewards and events offered by Daleelo Community Network and others, and provide news and information we think will be of interest to you;
  • Monitor and analyze trends, usage and activities in connection with our Services;
  • Audit related to a current interaction with the consumer and concurrent transactions, including but not limited to, counting ad impressions of unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards; 
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity; 
  • Debug to identify and repair errors impairing existing intended functionality; 
  • Undertake internal research for technical development and demonstration; 
  • Undertake activities to verify or maintain the quality or safety of a service owned, manufactured, manufactured for, or controlled by Daleelo Community Network, and to improve, upgrade, or enhance the service owned, manufactured, manufactured for, or controlled by Daleelo Community Network; 
  • Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Daleelo Community Network and others;
  • Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests; and
  • Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards; and

Please keep in mind that Daleelo Community Network does not trade or sellyour personal information.

9)     Transfer of Information to United States and OtherCountries

In order to provide youwith the Services you purchased or that you request from us, information aboutyou may be transferred to Daleelo Community Network locations in United States aswell as countries where our service providers may be based. In some cases,information about you may be transferred to or accessed from other countries,including when you consent and allow us to do so, where it is required in orderfor us to provide Services to you and when we need to do so to providefunctions like product support, troubleshooting and gaining insights into theusage patterns of our Services. When information about you is transferred tocountries other than your home country, you may not have the same rights andprotections as you do under local law. Any international transfers of suchinformation will be done in accordance with applicable law. 

10) California / Delaware Do Not Track Disclosures

Various third parties aredeveloping or have developed signals or other mechanisms for the expression ofconsumer choice regarding the collection of information about an individualconsumer’s online activities over time and across third-party web sites or onlineservices (e.g., browser do not track signals). Currently, Daleelo Community Network do not monitor or take any actionwith respect to these signals or other mechanisms.

11) Where we store your information

Daleelo Community Networkhas a data privacy officer who is responsible for ensuring that your personalinformation is collected, used, disclosed (shared) and retained in compliancewith applicable privacy regulations. However, the data that we collect from youmay be transferred to, and stored at, a destination outside the Europeaneconomic area ("EEA") that may not be subject to equivalent dataprotection law.

Where your information istransferred outside the EEA, we will take all steps reasonably necessary toensure that your data is subject to appropriate safeguards, such as relying ona recognized legal adequacy mechanism, and that it is treated securely and inaccordance with this privacy policy.

12)  How we secure information we collect

We use standard ISO 27001security technology to protect user data on the marketplace and have put inplace organizational measures to secure the information we collect on theApplication. While we implement safeguards designed to protect yourinformation, no security system is impenetrable and due to the inherent natureof the internet, we cannot guarantee that data, during transmissionthrough the internet or while stored on our systems or otherwise in ourcare, is absolutely safe from intrusion by others.

13) Provision of Personal Data and failure to providePersonal Data

Where we need to collectPersonal Data by law, or under the terms of a contract we have with you and youfail to provide that data when requested, we may not be able to perform the contractwe have or are trying to enter into with you (for example, to provide you withour services). In this case, we will not be able to provide services to you

14) How long we keep information

How long we keepinformation we collect about you depends on the type of information, asdescribed in further detail below.  After such time, we will either deleteor anonymize your information or, if this is not possible (for example, becausethe information has been stored in backup archives), then we will securelystore your information and isolate it from any further use until deletion ispossible.  

15) Blogs, Reviews and Forums

The Service also may fromtime to time offer publicly-accessible blogs, customer reviews or forums. Anyinformation you provide in these areas may be read, collected and used byothers who access them. To request removal of your Personal Information fromblogs, customer reviews or forums, please contact us. Please note that in somecases we may be unable to remove your Personal Information.

16)  Marketing information:

if you have elected toreceive marketing emails from us, we retain information about your marketingpreferences for a reasonable period of time from the date you last expressedinterest in our services, such as when you last opened an email from us or ceasedusing your Daleelo Community Network materials.  We retain informationderived from cookies and other tracking technologies for a reasonable period oftime from the date such information was created.   

17) How to access and control your information

You have certain choicesavailable to you when it comes to your information. Below is a summary of thosechoices, how to exercise them and any limitations.

18)  Consent to provide personal information

Weinform you when we need to collect your personal information and why we arecollecting it.

DaleeloCommunity Network only collects information from you after you give us yourconsent. The only exception is when the law requires the collection, use or disclosureof a person’s information without consent.

Providingus with personal information is entirely voluntary. By giving us your personalinformation, you consent to allow us to use and disclose your personalinformation as described to you. If you do not agree with the use anddisclosure of your information, please do not provide us with your personalinformation.

Someof our services can only be offered if you provide personal information so, ifyou choose not to provide your information, we may not be able to provide youwith those services.

Youmay withdraw consent at any time. You will be informed of the effect thatwithdrawing your consent will have. Your withdrawal of consent will only applyfrom the point that you withdrew consent. Your withdrawal of consent is notretroactive.

This means we will not remove information thathas already been disclosed.

19) Transfer to third parties

To facilitate thepurposes of our website, personal data may be shared in the normal course andscope of business with third parties to whom Daleelo Community Network haschosen to outsource work. In the event that personal data is transferred to athird party, Daleelo Community Network requires in its agreements with thirdparties that adequate privacy precautions are taken that provide the same levelof privacy protection as is required by the principles of the privacy shield.In certain circumstances, Daleelo Community Network may remain responsible andliable under privacy shield principles if such third parties process thepersonal data in a manner inconsistent with the privacy shield principles.Types of Third-party service providers are as follows:

A.    Service Providers: We share personal information about you withservice providers that help with our business activities, including drivers’ serviceproviders, billing and payment card processors, marketing and advertising serviceproviders, and companies that help us improve our products and services.

B.     Products Offered by Other Businesses: We will sometimes allow other businesses to maketheir products or services available to our customers, such as through Daleelo.comMarketplace. You may purchase items or services from these other businesses at ourstores or through our websites or mobile services. When you purchase theseproducts or services, we identify the other business and share with thisbusiness personal information related to your purchase of their products andservices.

C.     Legal Authority: We may share your personal information in situations when sharing isrequired by law, or we believe sharing will help to protect the safety,property, or rights of Daleelo Community Network, our customers, ourassociates, or other persons

We require ourthird-parties service providers to keep your personal information secure. We donot allow our service providers to use or share your personal information forany purpose other than providing services on our behalf. Your personalinformation may be stored and processed by our service providers in the United ArabEmirates or other locations where the service providers or Daleelo CommunityNetwork maintain facilities.

20) Your rights as a data subject

In some jurisdictions(for example, the member states of the European Union) you may be entitled tocertain rights in and to your personal data, subject to certain conditions andexceptions contained in applicable law. These rights may include the following:

  • Request us to confirmwhether your personal data is processed by us, and if we do, to obtain accessto your personal data and certain information about it.
  • Require the correction ofyour personal data if it is inaccurate or incomplete.
  • Direct us to stopprocessing your personal data under certain circumstances.
  • Erase or delete yourpersonal data, for example, where the data is no longer needed to achieve thepurpose for which it was collected.
  • Restrict the furtherprocessing of personal data
  • Request us not to besubject to a decision based solely on automated processing, includingprofiling, which produces legal effects concerning you or similarlysignificantly affects you (we currently do not engage in such processing andwill notify you prior to doing so).
  • Request to receive yourpersonal data for transmission to, or to directly transmit to, another datacontroller in a structured, commonly-used and machine-readable format.

To protect your privacyand the security of your personal data, we will take reasonable steps to verifyyour identity before complying with such rights requests.

21) Privacy shield

Daleelo Community Networkadheres to the seven privacy shield principles of notice, choice, andaccountability for onward transfer, security, data integrity, access, andrecourse, enforcement and liability as they relate to personal data. DaleeloCommunity Network verifies compliance to the principles throughself-assessment. The privacy policy covering human resources data can beaccessed on our intranet web site by all employees.

22)  Legal bases for processing (for EEA users)

If you are an individualin the European economic area (EEA), we collect and process information aboutyou only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the services you use and how you use them. Thismeans we collect and use your information only where:

  • We need it to provide you the services, including to operate the services, provide customer support and personalized features and to protect the safety and security of the services;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests;
  • You give us consent to do so for a specific purpose; or
  • We need to process your data to comply with a legal obligation.

If you have consented toour use of information about you for a specific purpose, you have the right tochange your mind at any time, but this will not affect any processing that hasalready taken place.  Where we are using your information because we or athird party (e.g. your employer) have a legitimate interest to do so, you havethe right to object to that use though, in some cases, and this may mean nolonger using the services

23) Our COPPA policy towards children

The services are not directedto individuals under the age of 13. We do not knowingly collect personalinformation from children under 13. Daleelo Community Network complieswith both the Children’s Online Privacy Protection Act of 1998 (COPPA) and,with regard to EU data subjects, with GDPR. While children under the age of thirteen(13) may use the Site only with the consent of his or her parent or legalguardian, please be advised that this Site is not directed or otherwisepromoted for use by children under the age of thirteen (13).

24) Residents of California

If you are a resident ofCalifornia, you have certain rights and protections under the CaliforniaConsumer Privacy Act (“CCPA”). Please read our California Privacy Rights

25) Your right to withdraw consent

Where the processing ofyour personal information by us is based on consent, you have the right towithdraw that consent without detriment at any time by contacting us. You canalso change your marketing preferences at any time as described in 'ourpromotional updates and communications' section.

You can also exercise therights listed above at any time by contacting us at Support@Daleelo.com. Ifyour request or concern is not satisfactorily resolved by us, you may contactour data protection officer, at Support@Daleelo.com.He can provide further information about your rights and our obligations inrelation to your personal data, as well as deal with any complaints that youhave about our processing of your personal data.

26) Opting out of messages from us

To opt-out of any futurepromotional messages from us, you should unsubscribe in the body of thepromotional message that was sent to you (found at the bottom of the email) orsend an unsubscribe request to us at Support@Daleelo.com. We will processyour request within a reasonable time after receipt.

27)  Data Privacy Regulatory Frameworks and Requirements

GDPR Data Privacy UserRights

Ifyou are an EU resident and Daleelo Community Network is processing, and/ortransmitting your personal data, then you - as an “EU data subject” – benefitfrom the following rights and privileges under the General Data ProtectionRegulation (GDPR):

  • Right of Access: you have the right to obtain from us, as controllers, confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the following personal data and information:
    1. the purposes of the processing;
    2. the categories of personal data concerned; i.e name, email, phone number etc
    3. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations’;
    4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
    5. the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing; (f) the right to lodge a complaint with a supervisory authority (for a list of supervisory authorities, see https://edpb.europa.eu/about-edpb/board/members_en);
    6. where the personal data are not collected from you, any available information as to their source;
    7. The existence of automated decision-making, including profiling, along the lines indicated by Article 22(1) and (4) GDPR, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
  • Right to Rectification: you have the right to obtain from us without undue delay the rectification of inaccurate personal data concerned, provided during registration by him or her. Taking into account the purposes of the processing, the user have the right to have request his incomplete personal data be completed, including by means of providing a supplementary statement.
  • Right to Erasure (“Right to be Forgotten): you have the right to obtain from us the erasure of your personal data without undue delay, and we have the obligation to erase personal data without undue delay when: a) your data are no longer necessary for the purposes for which they were collected; b) you had consented to the processing; c) you have objected to the processing, as per below; d) your persona data had been unlawfully collected; e) your personal data need to be erased as a matter of compliance with a legal obligation.
  • Right to Restriction of Processing: you have the right to obtain from us the restriction of processing if you: a) contest the accuracy of the personal data, until this is verified; b) the processing is unlawful but you don’t want erasure; c) we no longer need the personal data, but you require them to establish, exercise to defend a legal claim; d) you have objected to processing but there is a need to verify whether our legitimate grounds override your rights to object.
  • Right to Data Portability: where your personal data have been provided on the basis of your consent or for the performance of a contract, and their processing occurs in an automated way, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data– or have directly transmitted - to another controller.

Right to Object: you have the right toobject, on grounds relating to your particular situation, at any time toprocessing of your personal data based on a legitimate ground point (e) or (f)of Article 6(1), including profiling based on those provisions. In this case, wecan no longer process your personal data unless we show that there is acompelling legitimate ground for the processing which override your interests,rights and freedoms or for our establishment, exercise or defense of legalclaims.

28)  Data portability

Data portability is theability to obtain some of your information in a format you can move from oneservice provider to another (for instance, when you transfer your mobile phonenumber to another carrier).  Depending on the context, this applies tosome of your information, but not to all of your information.  Should yourequest it, we will provide you with an electronic file of your basic accountinformation and the information you create on the spaces you underyour sole control, like your personal bitbucket repository

29) Security and personal Information

The Site uses its bestendeavors to store all Personal Information on servers with restricted access,and all electronic storage and transmission of Personal Information are securedwith appropriate security technologies. In the interests of your security, weuses Secure ISO 27001 Socket Layer technology, to secure the data that wemanage within our website, reducing the risk of data breaches or errors.

With ISO 27001 in place,we are able to minimize risks to potential data security breaches and reduceerrors and costs, while demonstrating credibility and trust. You accept andacknowledge however that the internet is not a secure medium for thetransmission of information and data including personal data (PII) and suchinformation and data may be accessible by third parties.

30) Complaint To A Data Protection Authority

You have the right tosubmit a complaint concerning our data processing activities to our dataprotection officer

31) Contact us

If you have any queriesregarding our data collection and protection practices or your rights, pleasedo not hesitate to contact our data protection officer, at Support@Daleelo.com

32) Privacy policy changes

We may revise thisprivacy policy from time to time, and will post the most current version on ourweb site. If a revision meaningfully reduces your rights, we will notify you.