PRIVACY POLICY FOR THE TOUCH WALLET INFORMATION SYSTEM

1. DEFINITIONS OF TERMS

"Law" is the current legislation of the UAE with all changes and additions, as well as international treaties, conventions and other legislative acts in the field of protection of rights, dispute resolution and other legal issues.

"Information system" is software (with all existing additions and improvements). For the purposes of this Policy, the information system means the TOUCH WALLET mobile application and web service.

"Personal data" is a set of personal data and / or non-personalized information about the User provided by them to the Copyright Holder and / or automatically collected by the Copyright Holder and / or third parties.

"Policy" is this Information System Privacy Policy (with all existing supplements and changes).

"User" is a legal or natural person who has downloaded the information system and/or has activated it.

"User Agreement" is an agreement concluded between the Copyright Holder and the User regarding the procedure, rules and features of the User's use of the information system. The user joins such an agreement and does not have the right to make and / or demand any changes or additions to it.

"Copyright holder" is a person who owns the exclusive rights to own an information system.

2. RELATIONSHIPS TO WHICH THE POLICY APPLIES

General Provisions

This Policy is used and applicable exclusively to Personal Data received from the User in connection with their use of the information system. The provisions of this Policy are aimed at:

Determining the kinds and types of Personal Data received, the directions and purposes of using (processing) Personal Data, as well as the sources of obtaining such Personal Data;
Determining the User's rights regarding the protection of the confidentiality of the Personal Data provided by him;
Determining the persons responsible for the processing and storage of Personal Data, as well as third parties to whom such data is disclosed (in whole or in part).

The rules of this Policy do not apply in the case of processing by third parties of Personal data that is voluntarily provided by the User.

By installing and/or activating the Information System on a smartphone, tablet, watch or another mobile device, the User agrees to the terms of this Policy and gives his consent to the Copyright Holder for collecting, processing, retaining and storing Personal Data in the manner and under the conditions provided for in this Policy.

If the User does not agree with the terms of the Policy and / or individual terms of the Policy are not clear to him, they are obliged to immediately stop using the information system.

User Rights for the Protection of Personal Data

In connection with the provision of Personal Data, the User automatically receives the following rights:

To receive data regarding its processing (grounds and purposes of such processing, methods of processing used, information about persons who have access to it or to whom it can be disclosed on the basis of an agreement or the Law);
To receive data on the location and identification data of persons performing the processing of Personal Data;
To receive data on the storage period of Personal Data;
To receive information about the completed or potential cross-border transfer of Personal Data;
To appeal against the actions or inaction of the Copyright Holder to the authorized body for the protection of the rights of personal data subjects or in court;
To receive compensation for losses and / or compensation for moral damage in court due to violations of the User's rights to the protection of their Personal Data committed by the Copyright Holder and / or third parties;
To exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy;
To request the deletion of their personal data from the information system.

3. LIST OF PERSONAL DATA COLLECTED

Non-personally identifiable user information

In connection with the use of the information system, the Copyright Holder may automatically collect and process the following non-personalized information about the User:

Information about traffic, the possible number of clicks made, logs and other data;
Information about the User's location (geolocation). The user can disable geolocation at any time by changing the settings of the device on which he logged into the information system. Geolocation is used by the information system only when the User is actively using it. When you exit the information system, geolocation ceases to function.
Information about the device (identification number, mobile operator network) on which they log in, operating system, platform, browser type and other information about the browser, and the IP address.

Users’ Personal Data

The User provides the Copyright Holder with the following personal data:

Data on orders/purchases/transactions made by the User and/or services received/paid through the information system;
Data and information obtained as a result of combining certain Personal data of a particular User, as well as data and information about the User received from third parties (partners, marketers, researchers).

The User is the only person responsible for the completeness of the personal (personal) data provided and is obliged to change (update, check, correct) them in a timely manner on a regular basis.

The Copyright Holder assumes that all personal data provided by the User are reliable, and that the User keeps such information up to date.

Information About Completed Transactions

The User with the help of this information system can carry out transactions through available payment services.

The collection and processing of data about the User in this case is carried out solely for the purposes of conducting transactions, preventing fraud, as well as complying with other requirements of the Law.

The User consents to the access and collection of such Personal Data for the Copyright Holder and the relevant payment system through which payment is made, and also agrees to the privacy policy of the relevant payment system.

4. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA

Determining the Purposes of Processing

The collection and processing of Personal Data is carried out for the following purposes:

To analyze the User's behavior, as well as to identify the User's preferences for a particular type of content;
For the timely and correct operation of the information system, the improvement of the functioning of the information system, the content of the information system, the internal architecture and functionality of the information system;
To identify the User;
To show personalized advertising and marketing materials;
To send personalized advertising and marketing materials to the specified email address and / or mobile phone of the User;
To comply with the requirements of the Law;
To track orders / purchases / transactions made by the User through the information system, with the exception of transactions that are performed through the built-in mixer and are anonymous;
To determine the location of the User;
For technical support of the information system, identification of problems in its operation and their elimination;
To maintain contact with the User;
To fulfill other obligations of the Copyright Holder that arose before the User;
To conduct statistical research;
For any other purposes, subject to obtaining separate consent from the User.

The processing of Personal Data is carried out on the basis of the following principles:

Lawfulness of the purposes and methods of processing;
Good faith;
Compliance of the purposes of processing Personal Data with the purposes predetermined and declared when collecting such Personal Data;
Compliance of the volume and nature of the processed Personal data with the stated purposes of their processing.

Conditions for the Processing of Personal Data

Conditions for the Processing of Personal Data The processing of Personal Data is carried out in the following cases:

Obtaining consent from the User;
Pursuit by the Copyright Holder of the goals stipulated by an international treaty or the Law;
Providing the User with their Personal Data to an unlimited circle of persons;
Fulfillment of other obligations of the Copyright Holder to the User, including the provision of certain content to the User;
Saving the life or health of the User, when consent to the processing of his Personal Data cannot be obtained in advance.

In case of depersonalization of Personal Data, which does not allow to directly or indirectly identify the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy are no longer applied to it.

The Copyright Holder takes all possible measures to protect the confidentiality of the received Personal Data, except when the User has made such data publicly available.

The processing of Personal Data is carried out using automation tools and without their use.

5. USE OF COOKIES

A cookie is a small data file that a website asks your browser to store on your computer or mobile device. When a user revisits a website, the browser accesses the cookie database. Cookies allow a website to remember your actions or preferences for a long time.

The TOUCH WALLET web service uses certain Cookies to store the IP address, User preferences or the type of device used in order to:

Keep statistics of visits and website traffic;
Personalize the data displayed on the User's screen;
Save the data necessary to identify the User, including when accessed from different devices;
Show ads in accordance with the interests and preferences of the User.

The TOUCH WALLET web service can use both its own cookies belonging to the Copyright Holder and cookies of third parties.

6. USE OF CAPTCHAS

Captcha can be integrated into the information system, which is a type of Cookies, the purpose of which in this case is:

Protection of the User from possible spam coming from third parties on the Internet, as well as from other irrelevant and / or prohibited content;
Identification of the User in order to distinguish them from bots/robots;
Improving the User's ability to use the content of the information system.

Using Captchas, the system automatically accesses and collects the following information:

Cookies set in the browser within the last 6 (six) months;
The number of touches on the touchscreen of the device made by the User (the number of clicks made);
Information about the styling of the webpage;
Browser language settings;
Plugins installed in the User's browser;
All Javascript objects.

7. ACCESS OF THIRD PARTIES TO PERSONAL DATA

Using Remarketing Services

The Copyright Holder uses remarketing to advertise information system content to the User on other websites visited by the User.

Remarketing services are provided to the Copyright Holder through the Google Ads platform. Google Ads collects and processes non-personal data that does not directly allow the User to be identified or identified. The information collected may typically includes:

Content viewed by the User;
The date and time when the User viewed the content;
Geolocation data.

By installing the information system, the User agrees to the Privacy Policy for Google Ads and the Terms of Use for Google Ads, as well as to the automatic installation of appropriate Cookies on the User's device.

The user has the right to refuse advertising at any time by changing the appropriate settings of the browser and the device on which the information system is logged in.

Use of Analytical Platforms

The Copyright Holder can use analytical platforms to:

Track the frequency of website visits by Users;
Track how the User uses the information system and/or its content;
Identify of the type and kind of content that is popular among Users;
Determine the location of the User.

The User also gives his consent to the Copyright Holder to use the information received about the User from analytical platforms.

For these purposes, analytical platforms may collect data about the IP address, geolocation, the behavior of the User, as well as his preferences and interest in relation to certain content.

Analytical platforms get access to Personal data in order to provide the Copyright Holder with an understanding of how efficiently his information system works, what kind of content is popular, how effective it is to place this or that advertisement, as well as for the purposes of developing and/or improving an existing marketing strategy of the Copyright holder.

By installing the information system, the User agrees to the privacy policy of the analytical platform used, as well as to the automatic installation of appropriate Cookies on the User's device.

Disclosure of Personal Data to Third Parties

The Copyright Holder has the right to disclose Personal Data:

To its affiliates, branches and representative offices opened both in the territory of the UAE and in the territory of other States;
To successors of the Copyright Holder that arose as a result of its liquidation, reorganization or bankruptcy and received exclusive rights to own the information system;
To providers of payment services or banking (financial) institutions, to conduct transactions of the User through the information system;
To third parties solely for the purpose of obtaining certain content by the User or access to it;
To third parties, when the User has given consent to the disclosure, transfer or processing of their Personal Data, as well as in other cases expressly provided for by the Law or this Policy.

The Copyright Holder discloses Personal Data only:

Being sure that third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data that the Copyright Holder takes;
The agreement to such a disclosure having been expressed by the User beforehand and/or allowed based on the Law.

Advertising from Third Parties

The content of the information system may contain advertising banners and/or links to third party websites. The User's use of such websites (by clicking on a link or in any other way) may entail the collection, processing and use of Personal Data, as well as the possible automatic transfer of Cookies to the User's device on which the transfer to the website of third parties is made. The Copyright Holder does not bear any responsibility for the ways, methods or procedure for processing Personal Data by third-party websites. As a result, the Copyright Holder is also not a responsible person in case of disclosure of Personal Data to an unlimited circle of persons in connection with the use of such websites by the User.

The Copyright Holder strongly recommends that each User familiarize themselves in detail with the personal data protection policies of the websites used.

The User has the right to disable such advertising banners and/or links at any time.

8. PLACEMENT OF ADVERTISING

Advertising in the Information System

The Copyright Holder, along with the content, places various advertising and marketing materials in the information system, taking into account the identified preferences of the User to a particular content. Placement of advertisements in the information system involves the installation of certain Cookies on the Copyright Holder's device.

Distribution of Promotional Materials

With the installation of the information system on the device, the User automatically agrees with the Copyright Holder's right to send personalized advertising and marketing materials to the provided email address and/or mobile phone.

The user has the right to opt out of receiving such promotional and marketing materials at any time.

Please note that in case of refusal to receive advertising and marketing materials, the User may continue to receive any notifications from the Copyright Holder related to the use of the information system and/or its content.

9. TERM AND PROCEDURE FOR STORING PERSONAL DATA

The storage is carried out independently by the Copyright Holder

The information system collects and stores only the personal information which is necessary to provide the services of the Website or to execute agreements and contracts with the User, except when the law provides for the mandatory storage of personal information for a period specified by law.

.After the expiration of the period of storage of Personal Data, such data is subject to their immediate destruction or depersonalization, unless otherwise prohibited by the Law or the provisions of this Policy.

10. ACCESS OF MINORS TO THE INFORMATION SYSTEM

The information system cannot be used by persons under the age of 18.

11. PROCEDURE FOR PROTECTION OF PERSONAL DATA

Protecting the confidentiality of Personal Data is a paramount and important task for the Copyright Holder. The Copyright Holder adheres to all required international standards, rules and recommendations for the protection of Personal Data.

The Copyright Holder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure and unauthorized access by third parties.

Changing and Supplementing the Policy

This Policy is subject to change. The Copyright Holder does not bear any responsibility to the User for changing the terms of this Policy without the permission and / or consent of the User.

The user undertakes to regularly check the provisions of this Policy on their own for possible changes or additions.

The Risk of Disclosure

Regardless of the measures taken by the Copyright Holder to protect the confidentiality of the received personal data, the User is hereby considered to be properly aware that any transfer of Personal Data on the Internet cannot be guaranteed secure, and therefore the User carries out such transfer at their own risk.

12. CONTACT DATA

Copyright Holder: Cloud Farmer LLC-FZ
Address: Business Center 1, M Floor, The Meydan Hotel, Nad Al Sheba, Dubai, UAE
e-mail: ceo@cloudfarmer.info