1. Introduction

1.1 We are committed to safeguarding the privacy of our platform 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 platform. / By using our platform and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy. 

1.3    your acceptance of this Policy is considered to be an approved and signed electronic signature in our electronic system and confirms the validity of this policy, by applying the provisions of Law No. 20/2014 for electronic transactions. 

1.4   All electronic data, information provided, offered, submitted, presented, shared, kept, used in or through the platform are governed with the terms of the regulation 42/2021 in regards to privacy protection. 

1.5    This policy shall be governed by and construed in accordance with [Kuwaiti laws]. 

1.6    Any disputes relating to this policy shall be subject to the jurisdiction of Kuwait courts. 

2. Collecting personal information

2.1 We 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 platform (including [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and platform navigation paths]) 

(b) Information that you provide to us when registering with our platform (including [your email address] 

(c) Information that you provide when completing your profile on our platform (including [your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details]) 

(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 platform, 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 platform (including [your name, address, telephone number, email address and card details]);] 

(g) [information that you post to our platform 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 platform (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].] 

2.2 Before 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

3.1 Personal information submitted to us through our platform will be used for the purposes specified in this policy or on the relevant pages of the platform. 

3.2 We may use your personal information to:  

(a) [administer our platform and business;] 

(b) [personalise our platform for you;] 

(c) [enable your use of the services available on our platform;] 

(d) [send you goods purchased through our platform;] 

(e) [supply to you services purchased through our platform;] 

(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 platform;] 

(m) [keep our platform secure and prevent fraud;] 

(n) [verify compliance with the terms and conditions governing the use of our platform [(including monitoring private messages sent through our platform private messaging service)]; and] 

3.3 If you submit personal information for publication on our platform, we will publish and otherwise use that information in accordance with the license you grant to us. 

3.4 Your privacy settings can be used to limit the publication of your information on our platform, and can be adjusted using privacy controls on the platform. 

3.5 We 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. 

3.6 All our platform 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 platform, refunding such payments and dealing with complaints and queries relating to such payments and refunds. 

4. Disclosing personal information

4.1 We 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. 

4.2 We 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. 

4.3 We 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] 

4.4 Except as provided in this policy, we will not provide your personal information to third parties.

5. International data transfers

5.1 Information 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. 

5.2 Personal information that you publish on our platform or submit for publication on our platform may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others. 

5.3 You expressly agree to the transfers of personal information described in this Section 6. 

6. Retaining personal information

6.1 This Section 6 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. 

6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 

6.3 Without prejudice to Section 6.2 , we will usually delete personal data falling within the categories set out below at the date/time set out below:  

(a) [personal data type] will be deleted [date/time; and] 

6.4 Notwithstanding the other provisions of this Section 6, 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

7.1 We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information. 

7.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers. 

7.3 All electronic financial transactions entered into through our platform will be protected by encryption technology. 

7.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. 

7.5 You are responsible for keeping the password you use for accessing our platform confidential; we will not ask you for your password (except when you log in to our platform). 

8. Amendments

8.1 We may update this policy from time to time by publishing a new version on our platform. 

8.2 You should check this page occasionally to ensure you are happy with any changes to this policy. 

8.3 We may notify you of changes to this policy [by email or through the private messaging system on our platform]. 

9. Your rights

9.1 You may instruct us to provide you with any personal information we hold about you. 

9.2 We may withhold personal information that you request to the extent permitted by law. 

9.3 You may instruct us at any time not to process your personal information for marketing purposes. 

9.4 In 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 platforms

10.1 Our platform includes hyperlinks to, and details of, third party platforms. 

10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties. 

11. Updating information

11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated. 

12. Cookies

12.1 Our platform uses cookies. 

12.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a platform server to a platform 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. 

12.3 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a platform 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 platform browser is closed.  

12.4 Cookies 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. 

12.5 We use [only session cookies / only persistent cookies / both session and persistent cookies] on our platform. 

12.6 The names of the cookies that we use on our platform, and the purposes for which they are used, are set out below:  

(a) we use [cookie name] on our platform to [recognize a computer when a user visits the platform / track users as they navigate the platform / enable the use of a shopping cart on the platform / improve the platform’s usability / analyze the use of the platform / administer the platform / prevent fraud and improve the security of the platform / personalize the platform for each user / target advertisements which may be of particular interest to specific users / [describe purpose(s)]]; 

12.7 Most browsers allow you to refuse to accept cookies. 

12.8 Blocking all cookies will have a negative impact upon the usability of many platforms. 

12.9 If you block cookies, you will not be able to use all the features on our platform. 

12.10 You can delete cookies already stored on your computer. 

12.11 Deleting cookies will have a negative impact on the usability of many platforms. 

13. Our details

13.1 This platform is owned and operated by ……. 

13.2 We are registered in [Kuwait] under registration number […….], and our registered office is at [………..]. 

13.3 You can contact us by writing to the business address given above, by using our platform contact form, by email to [email address] or by telephone on [telephone number]. 


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