We, Supa Dalali Advertising Platform ("Supa Dalali", "we" or “us”),
aim to protect your privacy to the maximum extent possible under the applicable law. The
objective of the below privacy policy (the “Policy”) is to protect your privacy and to
explain and guide you through the process in which your personal information is used
throughout our downloadable mobile application and any additional websites owned and
operated by Supa Dalali, and Supa Dalali’s other services referred to in the app and the
website (collectively: “Services”). Our Services mainly include advertising through the
internet and other telecommunications, using a platform which is designated to connect
operators of merchant accounts to operators of user accounts, but we may expand the scope of
Supa Dalali’s services as we deem fit.
In this Policy, we will explain to you how Supa Dalali receives, collects, stores, uses, discloses and protects personal information about any person who uses our Services. Personal information is information that could reasonably allow you to be identified (including, for the avoidance of doubt, a combination of pieces of information that, combined together, could reasonably allow you to be identified).
As a precautionary measure, if you have any doubts about any of your rights
and obligations under the Policy, you are hereby advised not to proceed without consulting
with a legal counsel. If you do not agree with this Policy or any of its contents, whether
now or in the future, you are hereby advised to immediately cease from using our
Services.
It shall be expressly noted that this Policy is an integral part of the
Terms and Conditions of Supa Dalali’s app, website and their ancillary services.
1. Acceptance of the Policy.
1.1 By electronically
accepting, installing, accessing or using the Services (including by visiting our website)
you:
(a) acknowledge that this Policy will apply to your use of our Services as for
the moment you access our app, website or any other Service (as applicable);
(b)
hereby agree to be bound by this Policy, which shall constitute an agreement between you and
Supa Dalali; and
(c) acknowledge and agree that this Policy shall apply to all
personal information transmitted by you to Supa Dalali.
2. Scope of Application
2.1 This Policy applies to
all personal information transmitted by you to Supa Dalali, whether in the course of
visiting our app and/or website and/or using any other of our Services, using our app as a
registered user, using our website as a registered user, using any other Services or via any
other method of transmission permitted under the terms and conditions of our
Services.
2.2 This Policy also applies to:
(a) information that Supa Dalali
collects via e-mail, text, photos and other electronic messaging between you and Supa
Dalali; and
(b) interactions between you and third-party webpages or apps that
include a link to this Policy.
2.3 It is hereby expressly warranted that Supa Dalali
is not, nor shall be in the future, responsible for the privacy rules and regulations of any
third-party app, website and/or service, regardless if such third-party app, website and/or
service was linked from and/or through Supa Dalali’s app, website and/or any other Services.
The foregoing sentence shall extend also to any person employed or otherwise engaged under
the payroll by such third-party.
3. Collected Information
3.1 Supa Dalali collects
personal information from you through various sources, whether directly when opening an
account on any of our Services or indirectly, as described below.
3.2 Supa Dalali
will collect your personal information in the following ways:
(a) Information that we
receive from you
(i) Account Registration. In order for you to create an account in
our app, website and/or in any other of our Service, you may be required to provide Supa
Dalali with certain information such as your name, date of birth, gender, work title, the
organization in which you are employed, e-mail address, company registration number, VAT
number, residential address, office address, mobile and landline numbers and the like. Such
information will be provided to us either by filling in forms on our app and/or on our
website and/or when subscribing for any Service, or in any other way as we deem
fit;
(ii) Payment Information. In order to transfer to you any monetary amount which
you may be entitled to (if applicable), or to receive from you any monetary amount which you
shall transfer to Supa Dalali under any agreement (if applicable), Supa Dalali may require
you to provide certain information, such as your bank account details, credit card name and
number, bank sort code, IBAN, CVC, CVV, card expiry date, billing information, copies of
identification documents (such as passport copy and utility bill), and any other information
you provide us in order to prove your eligibility to use Supa Dalali’s Services and the
like. When making a payment on someone’s behalf, please ensure that you have his/her
permission; and
(iii) Your Generated Content. Certain parts of our Services would
require you to send Supa Dalali content such as including photos, videos, texts and other
materials (“User Content”). Such User Content will be sent to us via the relevant fields in
the App or Website (as applicable).
3.3 Please note that your payment
information may be required for payment processing, however it shall be noted that Supa
Dalali does not store credit card details.
3.4 In the event where you do not wish to
disclose any of the above personal information but you are unable to execute any action
required under the Services without disclosing such personal information, you may contact us
at the e-mail complaines@Supa Dalali.com and notify Supa Dalali of such malfunction.
4. Use of Collected Data
You hereby agree that Supa
Dalali may use your personal information for the following purposes:
4.1
personalizing your experience and ensuring that the contents of our app, website our other
Services will be presented to you in the most efficient manner;
4.2 enhancing our
Services;
4.3 developing new Services and/or notifying you about changes to our
Services;
4.4 developing new tools in our Services;
4.5 improving the infrastructure
of our Services;
4.6 analysing the conducting system analytics;
4.7 enhancing Supa
Dalali’s customer services;
4.8 contacting you with marketing offers which may be of
interest of you (unless you have been opted out of marketing, or we are otherwise prevented
by law from doing so)
4.9 making the Services more secure for the users;
4.10
verifying your identity to protect against fraud and to confirm your eligibility to use our
Services; and
4.11 any similar action not specifically mentioned in the above.
5. Informational Data Transfer
5.1 We operate and a
global business, and therefore, in order to provide Supa Dalali's services, we may need to
have your personal information processed outside of the European Economic Area (EEA). In
case you do not wish to have your personal information processed outside of the EEA, please
cease immediately from using Supa Dalali’s Services.
6.
Children
Supa Dalali’s Services are not targeted for any person under
the age of 16, and Supa Dalali will make all reasonable efforts required to not collect any
information regarding any person under that age. In the event Supa Dalali unintentionally
receives any information from or about a child under the age of 16, Supa Dalali will procure
that all necessary actions are made so that such information is deleted without undue delay
(but at all times, subject to the restrictions of the applicable law).
7. Miscellaneous
7.1 Nothing in this Policy
shall:
(a) be construed as creating any agency, arrangement, partnership, joint
venture, trust of fiduciary relationships or any other similar relationship between you and
Supa Dalali; and
(b) create or confer any rights or benefits to any third-party, or
grant you any security interest in any asset of Supa Dalali.
7.2 This Policy has been
drafted in the English language. In the event of any discrepancy between the meanings of any
translated versions of this Policy and the English language version, the meaning of the
English language version shall prevail.
8. Amendments
8.1 We
may change this Policy at any time by post those changes on the app and/or website and/or
any other Service (as applicable), so that you shall always be aware of those changes. The
changes take effect immediately once they are published the relevant Service, with the
indication of the date in which those changes were made. These changes will supersede any
prior changes.
8.2 Where a change of this Privacy Policy constitutes a material
change which has a significant impact on your rights, we will give you an advance notice so
that you will be able to exercise your rights of objection (as well as any other right)
prior to the change. If you continue to use our Services after Supa Dalali posts the changes
to this Policy, it will indicate that you accepted those changes and the Policy as a
whole.
9. Access to Your Data / Your Rights over the Personal Information
9.1 Supa Dalali does not have direct relationship with the personal information that
we process. Therefore, you may:
(a) where you feel that our use of your personal information impacts any of
your fundamental rights, object to processing of your personal information;
(b) receive a copy of your personal information that Supa Dalali holds;
(c) request that we correct the personal information that we hold about you
(subject to Supa Dalali's right to verify the new personal information that you
provide);
(d) request that we withdraw your consent of the processing of your personal
information (but you acknowledge and agree that exercising this right will not
affect the lawfulness of processing of your personal information prior to the
date of withdrawal);
(e) ask us to restrict the processing of your personal information;
(f) request that we transmit your personal information to a third party (subject
to our right to investigate if such third party is permitted to receive such
personal information);
(g) request Supa Dalali to erase and/or remove any or all of your personal
information; and
(h) lodge a compliant with your local data protection authority.
9.2 We will keep your personal information for as long as we have a relationship with
you. Once our relationship with you has come to an end, we will retain your personal
information for a period of time that enables us to:
(a) maintain business records for analysis and/or audit purposes;
(b) comply with record retention requirements under the law;
(c) defend or bring any existing or potential legal claims;
(d) deal with any complaints regarding our Services; and
(e) any other purposes for which personal information will be retained.
9.3 We will delete your personal information when it is no longer required for these
purposes. If there is any information that we are unable, for technical reasons, to
delete entirely from our systems, we will put in place appropriate measures to
prevent any further processing or use of the personal information.
9.4 You should note that Supa Dalali:
(a) may not always be able to comply with your said request for specific legal
reasons. Supa Dalali will notify you of the nature of such non-compliance; and
(b) may not be able to provide you Supa Dalali's services in case you request
that we effect any of the following actions set above in this clause (and
therefore we may need to terminate your Supa Dalali's account).
10. Information Security
10.1 All of your personal information transmitted to Supa Dalali will be stored in
secure services. We will use our best efforts to protect your personal information,
however you shall be aware that the internet is not completely secured and therefore
we can not guarantee a bulletproof security of your personal information. Therefore,
you hereby acknowledge that any transmission of your personal information is made
at your own risk.
11. Contact Us
11.1 Supa Dalali is the data
controller of the personal information that you transmit to the app and/or website and/or
any other Services in the course of the operations of the app and/or website and/or the
other applicable Service (as applicable).
11.2 If you have any doubts about any of
your rights and obligations under the Policy, you may contact us at legal@supa-dalali.net or martinrowlandb@gmail.com
11.3 In compliance with the General Data Protection Regulation (GDPR) (EU)
2016/679 which can be found in the following link
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679, we have appointed a
data protection officer ("DPO"). In the event where you have any questions relating to your
rights and obligations set out in this Policy, you may contact us at legal@supa-dalali.net or martinrowlandb@gmail.com.
11.4 Supa Dalali is devoted to obtaining an equitable
resolution regarding any concern and/or complain regarding your privacy. If you believe that
your concern and/or complain has not been satisfied by us under this Policy or following a
correspondence with Supa Dalali’s designated personnel, you shall, in all cases, have the
right to report or file a compliant to the applicable data protection authority in your
company of residence (using such authority’s website).
This Policy shall be deemed
effective as of January 23, 2022.