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This policy, together with our terms and conditions applies to your use of:

  • Whipp mobile application software (App) once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
  • Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 09/30/2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you [when you next start the App or log onto one of the Services Sites]. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you as follows:

● Identity Data.

● Contact Data.

● Financial Data.

● Transaction Data.

● Device Data.

● Content Data.

● Profile Data.

● Usage Data.

● Marketing and Communications Data.

● Location Data


HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

● Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App's social media functions, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.

● Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.

● Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

● Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below:

● Device Data from the following parties:

analytics providers;

advertising networks; and

search information providers.

● Contact, Financial and Transaction Data from providers of technical, payment and delivery services;


COOKIES

We use cookies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.


HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

● Where you have consented before the processing.

● Where we need to perform a contract we are about to enter or have entered with you.

● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

● Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.


DATA SECURITY

All information you provide to us is stored on our secure servers. Any payment transactions [carried out by us or our chosen third-party provider of payment processing services] will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access the App and its Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.


DATA RETENTION

We may keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 5 years after they cease being customers.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 2 years then we will treat the account as expired and your personal data may be deleted.


EXTERNAL THIRD PARTIES

Service providers [acting as processors] based in [Kuwait] who provide [IT and system administration services].

Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in [Kuwait] who provide [consultancy, banking, legal, insurance and accounting services].

[DETAILS OF ANY OTHER THIRD PARTIES, FOR EXAMPLE, MARKET RESEARCHERS, FRAUD PREVENTION AGENCIES, PRICE COMPARISON SITES AND SO ON.]


YOUR LEGAL RIGHTS

You have the right to:

● Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

● Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

● Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

● Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

● Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a)if you want us to establish the data's accuracy;

(b)where our use of the data is unlawful but you do not want us to erase it;

(c)where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d)you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

● Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

This policy, together with our terms and conditions applies to your use of:

● Whipp Captain mobile application software (App) once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

● Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 09/30/2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you [when you next start the App or log onto one of the Services Sites]. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.


Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.


THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you as follows:

● Identity Data.

● Contact Data.

● Financial Data.

● Transaction Data.

● Device Data.

● Content Data.

● Profile Data.

● Usage Data.

● Marketing and Communications Data.

● Location Data


HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App's social media functions, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.

Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.

Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below:

● Device Data from the following parties:

analytics providers;

advertising networks; and

search information providers.

● Contact, Financial and Transaction Data from providers of technical, payment and delivery services;


COOKIES

We use cookies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.


HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

● Where you have consented before the processing.

● Where we need to perform a contract we are about to enter or have entered with you.

● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

● Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.


DATA SECURITY

All information you provide to us is stored on our secure servers. Any payment transactions [carried out by us or our chosen third-party provider of payment processing services] will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access the App and its Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.


DATA RETENTION

We may keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 5 years after they cease being customers.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 2 years then we will treat the account as expired and your personal data may be deleted.


EXTERNAL THIRD PARTIES

Service providers [acting as processors] based in [Kuwait] who provide [IT and system administration services].

Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in [Kuwait] who provide [consultancy, banking, legal, insurance and accounting services].

[DETAILS OF ANY OTHER THIRD PARTIES, FOR EXAMPLE, MARKET RESEARCHERS, FRAUD PREVENTION AGENCIES, PRICE COMPARISON SITES AND SO ON.]


YOUR LEGAL RIGHTS

You have the right to:

● Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

● Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

● Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

● Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(a) you want us to establish the data's accuracy;

(b) our use of the data is unlawful but you do not want us to erase it;

(c) you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d)you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

● Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.