PRECONDITIONS

ADJO Digital DMCC or any (“ADJO” or “we” or “us” or “our”) know that your privacy is important. This privacy policy (“Policy”) is designed to assist you in understanding how we will collect and use the information you provide when you use (i) our publicly available websites (the “Sites”) and (ii) the ADJO Mobile and other add-on applications (e.g., ADJO Mobile for iOS®, ADJO Mobile for Android™, etc.) (“Apps”) and other related services on which we post a direct link to this privacy policy (together with Apps, the “Services”).

Please read this Policy to learn more about the ways in which we collect and use your information. If we make any material changes to this Policy, we will notify you in accordance with the process described in the “Revisions or Changes” section of this Policy, below. By using our Services, you consent to our collection, use, and disclosure of your information as described in this Policy.

This Policy does not cover any other data collection or processing, including without limitation the data we host for our registered customers via the ADJO software platforms (“Platform”). If you use our Platform, the data that you (and your customers) submit as you use our Platform will be governed by the applicable ADJO agreement, and as required by law.

For the purposes of our Policy, when we refer to “you” or to a “customer” we mean any past, current or prospective customer of ADJO, including any visitor to one of our Sites.

DATA CONTROLLER AND PRIVACY OFFICER

ADJO, as identified at the top of this Policy, is the data controller regarding all personal information processing carried out through the Services. To get in touch with ADJO’s Privacy Officer, please contact: legal(At)adjo(Dot)cc

COLLECTION OF PERSONAL INFORMATION

What we collect. In some situations you may provide us with your personal information, which could include your name, company name, company identification number, street address, telephone number, mobile number, e-mail address, job title, preferred mode of payment, account number(s) and any other information we collect about you that by itself is not personal information but if combined with personal information could be used to personally identify you.

You may provide us with personal information when you complete a survey; apply for a job via the Sites or Apps; request customer support; subscribe to certain Services, e-mail notifications and/or newsletters; register for our Services, or register and/or set up an account/profile to access, visit and/or use certain portions of our Sites or Apps; provide comments, reviews, feedback, or testimonials about our products or Services; and any other transactions between you and us on or in relation to our Services.

We may use your e-mail and other addresses and contact information for customer support, required notifications, product and policy updates and marketing releases, but we will not use this information for anything else not described in this Policy.

Information We Automatically Collect. When you access our Sites or Apps whether by computer, mobile phone or other device, we automatically collect certain information about your use of our Sites or Apps (this information may include without limitation: geographical location and IDs of your computer, mobile or other device; bandwidth used; system and connection performance; browser type and version; operating system; referral source; length of visit; page views; IP address or other unique identifier for your computer, mobile phone or other device; your mobile carrier) using technologies such as cookies and web beacons. When you download and use our Apps, we may also collect additional information about your mobile device, including the hardware model, operating system and version, mobile network information and time zone.

Other Persons. In any situation where you decide to share personal information related to other persons, you will be considered as an independent data controller regarding that personal information and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify ADJO against any complaints, claims or demands for compensation for damages which may arise from the processing of this personal information, brought by the third parties whose information you provide through the Sites or Services.

As ADJO does not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties' consent before providing any information regarding them to ADJO; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give ADJO this information.

Refer a Friend. If you choose to use our referral service to tell a friend about our Services, we will ask you for your friend's name and e-mail address. We will use the information you provide to automatically send your friend an e-mail inviting him or her to visit our Sites or Apps. Your friend can opt out of receiving future promotional/marketing messages from us by clicking the “Unsubscribe” link found in the footer of our e-mail messages. Your friend may also contact us using the information in the “How to Contact Us” section of this Policy, and request that we remove their information from our database. Treatment of your friend's information will be subject to the terms of this Policy.

PURPOSE OF PROCESSING PERSONAL INFORMATION

Service Provision. To verify your identity and assist you in case you lose or forget your login / password details for any of ADJO's registration services, to allow you to consult your Service history, by maintaining a registered user profile, to send you ADJO newsletter you subscribed for as a service and which contains only informative material, to send you any information you explicitly requested; to finalise your order and to provide any other Services which you may request.

Marketing. For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail, SMS, over the phone, banners instant messaging, through an operator, traditional mail, through ADJO’s official social media pages, regarding ADJO‘s Services, as well as those of selected third parties.

Profiling. To create a profile of you as a Site or App user, through the use of profiling cookies and by collecting and analysing information on the preferences you select and choices you make in the Site or App, as well as your general activities on the Site or App. This profile will be used to enhance your experience and give you information about Services which ADJO believes you may be interested in, and to show you information and advertisements which may be relevant to you and your interests.

Compliance. For compliance with laws, which impose upon ADJO the collection and/or further processing of certain kinds of personal information.

Misuse/Fraud. To prevent and detect any misuse of the Sites or Apps, or any fraudulent activities carried out through the Sites or Apps.

HOW WE USE PERSONAL INFORMATION

General. ADJO may use personal information to respond to your inquiries, and/or address other requests or questions; enable your use of the Services; contact you regarding your Services; consider and respond to your job application; and collect payments from you; and to deliver Services ordered through our Sites or Apps; information and updates related to your Services; invoices; e-mail notifications that you have specifically requested; e-mail marketing communications relating to our business, which we think may be of interest to you; and e-mail messages containing company news, product or service information. We may also use information collected through our Sites or Apps for research regarding the effectiveness of the Sites or Apps and related marketing, advertising and sales efforts. We may disclose your personal information (i) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders; (ii) if we sell or transfer all or a portion of our company's business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change, or (iii) as otherwise disclosed in the terms and conditions of our agreements with customers, including our separately posted and applicable Addendum for the relevant Services.

Service Provision

Processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give ADJO your personal information for these purposes; however, if you do not, ADJO will not be able to provide any Services to you.

Marketing

Processing for these purposes is based on your consent. It is not mandatory for you to give consent to ADJO for use of your personal information for these purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from ADJO). Any consent given may also be withdrawn at a later stage.

Profiling

Processing for this purpose is based on your consent collected by means of the banner cookie and/or with a specific tickbox. It is not mandatory for you to give consent to ADJO for use of your personal information for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the Sites or Apps). Any consent given may also be withdrawn at a later stage. Compliance. Processing for this purpose is necessary for ADJO to comply with its legal obligations. When you provide any personal information to ADJO, ADJO must process it in accordance with the laws applicable to it, which may include retaining and reporting your personal information to official authorities for compliance with tax, customs or other legal obligations.

Misuse/Fraud

Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Sites or Apps.

Disclosures to Third Parties | General

We may disclose information collected from a customer to our independent contractors and business partners who have agreed to (i) hold this information in confidence, and (ii) not use it for any purpose except to carry out the services they are providing for ADJO. Such contractors and business partners include those hosting our Services or other data; managing the functionality of our Services; hosting customer relationship management, marketing automation, marketing channels, customer service and other software platforms on our behalf; processing credit or other payment card payments; collecting delinquent accounts; fulfilling and processing orders; conducting background checks if you submit an application for employment; assisting with marketing and promotions; and enabling us to send you e-mail.

Disclosures to Third Parties | Specific

ADJO has a number of partner programs designed to maximize our customers' ability to use our Services and to order services that may be used in tandem with our Services. We may disclose information collected from a customer to one or more trusted partners for the purpose of such partner(s) providing assistance to the customer in its use of the Services and for the purpose of marketing complementary or value-add products and services to the customer. In each case such trusted partner will have agreed to (i) hold this information in confidence, and (ii) not use it for any purpose except for the purposes described above.

Transfer of Personal information

Considering ADJO’s worldwide presence and business operations, your personal information may be transferred to recipients located in several different countries. ADJO implements appropriate safeguards to ensure the lawfulness and security of these personal information transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand. More information about it are available sending a written request to personal information at the following address: legal(At)adjo(Dot)cc.

Disclosures of Aggregate Information

ADJO may also disclose aggregate, anonymous data based on information collected from customers. Should a sale of ADJO's business ever occur, collected customer information may be transferred along with the sale but the information will be treated in the same manner as set forth in this Policy. In the event of any significant changes to the manner in which your information is handled, we would notify you by a prominent notice on the Sites or Apps, or by e-mail.

Disclosures Made by You within Interactive Areas of a Site or App

If you use a bulletin board, blog, comment or discussion forum or chat room made available on a Site or App, you should be aware that any personal information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages, and could be potentially searchable through search engines. We are not responsible for the potential misuse by third parties of any personal information that you choose to submit in these various forums.

Retention of Personal information

Personal information processed for service provision will be kept by ADJO for the period deemed strictly necessary to fulfil such purposes – in any case, as these personal information are processed for the provision of the Services, ADJO may continue to store this personal information for a longer period, as may be necessary to protect ADJO’s interests related to potential liability related to the provision of the Services. Personal information processed for marketing and profiling will be kept by ADJO from the moment you give consent until the moment you withdraw the consent given and renewed at fixed intervals. Once consent is withdrawn, Personal information will no longer be used for these purposes, although it may still be kept by ADJO, in particular as may be necessary to protect ADJO’s interests related to potential liability related to this processing. Personal information processed for compliance will be kept by ADJO for the period required by the specific legal obligation or by the applicable law. Personal information processed for preventing misuse/fraud will be kept by ADJO for as long as deemed strictly necessary to fulfil the purposes for which it was collected.

OTHER GENERAL POLICIES RELATING TO PRIVACY

Disclosures by Children

We believe that protecting the privacy of the very young is especially important and for that reason we will never collect or maintain information on our Site or App from those we actually know are under the age of 13, and no part of our Site or App is structured to attract anyone under 13.

Third Party Sites or Apps

Our Sites or Apps may contain links to third party websites. Please note that the privacy and other policies of any such third party website may differ materially from this Policy. We strongly recommend that customers review the privacy policies of any such third party prior to submitting personal information. ADJO has no control over and is not responsible for the information practices of other websites, including those to which we may link and those which may link to us.

Use of Widgets

We may provide widgets on our Sites or Apps that make it possible to share information on third-party platforms. These widgets do not store your personal information. Our Sites or Apps may also include social media features, and similar widgets and interactive mini-programs that run on our site (each, a Feature). To the extent we use these Features, they may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social media Features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy statement of the company providing the Feature or widget.

Use of Cookies

When you interact with the Site, we try to make that experience simple and meaningful. When you visit our Site, our web server sends a cookie to your computer. Cookies are files that web browsers place on a computer's hard drive and are used to indicate whether you have visited the Site previously. The data collected may include how you navigate around a web page and the most commonly clicked links on a specific web page. Certain technical information, such as your browser version and operating system, are also collected. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set (each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences). We use cookies for a number of purposes, including to: access a customer's account information when a customer logs into a Site, so that we can provide the customer with customized content, keep track of preferences you specify while you are using the Services, and to estimate and report total audience size (unique users) and traffic for our Sites, and to conduct research to improve the content and services of our Sites.

Web Beacons

We may use web beacons (also known as clear GIFs) to access cookies and count users who visit our Sites or open our HTML-formatted e-mail messages. Web beacons are single-pixel graphic files with a unique identifier, similar to cookies. Web beacons are embedded invisibly on web pages and e-mails and are stored on a user's hard drive. You can modify your browser settings to control web beacons.

Third-Party Cookies

We may also from time to time engage third parties to track and analyze non-personally identifiable usage and volume statistical information from visitors to our Sites to help us administer our Sites and improve their quality. Such third parties may use cookies and web beacons to help track visitor behavior. Such cookies and web beacons may track how you interact with a Site through the use of cookies and the data collected may include how you navigate around a web page and the most commonly clicked links on a specific web page. Certain technical information, such as your browser version and operating system, may also be collected. If collected, this information will be used by us to evaluate and, if necessary, modify the relevant Site to improve the functions and ultimately, make it easier for customers to use. None of your personal information, that is, your name, address, or phone number, is collected through such collections.

Behavioral Targeting/Re-Targeting

We partner with third party ad networks to either display advertising on our Sites or Apps or to manage our advertising on other websites. Our ad network partners may use cookies and web beacons to collect non-personal information about your activities on our Sites and other websites to provide you targeted advertising based upon your interests. Even if you opt out through any third party ad networks, you can still receive communications you have signed up to receive from us unless you opt out of those by using the information in the “Data Subjects’ Rights and Opting Out” section of this Policy.

Use of Testimonials

We may select and post customer testimonials on our Services, which may contain personal information such as your name and/or the city, state, or country in which you live. We will obtain your consent prior to posting any testimonial with your name. If you post such content, it will be available to other users of the Services. Your posting may also become public and we cannot prevent such information from being used in a manner that may violate this Policy or the law. If you would like us to remove or delete your name or testimonial from our Services, you may contact ADJO using the information in the “How to Contact Us” section of this Policy. Note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of our Sites or Apps for a period of time.

Reviews

We may post customer reviews on our Sites or Services, which may contain personal information such as your name and/or the city, state, or country in which you live. When submitting your review you are giving us permission to post your review on our Sites or Services. If you post such content, it will be available to other users of the Sites or Services. Your posting may also become public and we cannot prevent such information from being used in a manner that may violate this Policy or the law. If you would like us to remove your name or review from our Sites or Services, you may contact ADJO using the information in the “How to Contact Us” section of this Policy. Note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of our Sites or Apps for a period of time.

Governing Law; Superseding Contract Terms

By choosing to visit and interact with ADJO, you agree that your visit and any dispute regarding the protection of your privacy during such visit is subject to this Policy and the dispute resolution provisions in our separate addendum applicable to the Services relating to the dispute. Please note that to the extent a customer enters into other contractual agreements with ADJO, the privacy terms and conditions of such agreements (including the separate addendum applicable to the relevant Services) may by express reference supplement or supersede portions of this Policy. Data Subjects’ Rights and Opting Out. Under the regulation, you, as a data subject, are entitled to exercise the following rights before ADJO and at any time access your personal information being processed by ADJO (and/or a copy of that personal information), as well as information on the processing of your personal information; a) Correct or update your personal information processed by ADJO, where it may be inaccurate or incomplete; b) Request erasure of your personal information being processed by ADJO, where you feel that the processing is unnecessary or otherwise unlawful; c) Request the restriction of the processing of your personal information, where you feel that the personal information processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing; d) Exercise your right to portability: the right to obtain a copy of your personal information provided to ADJO, in a structured, commonly used and machine-readable format, as well as the transmission of that personal information to another data controller; e) Object to the processing of your personal information, based on relevant grounds related to your particular situation, which you believe must prevent ADJO from processing your personal information; or f) Withdraw your consent to processing (for marketing and profiling).

Please note that most of the personal information you provide to ADJO can be changed at any time, including your e-mail preferences, by accessing, where applicable, the user profile you can create on the Sites or Apps. When requesting for the Services, you may have selected the means of communication through whom you desired the marketing to be carried out (i.e. fax, phone, SMS, e-mail, mail, social media). You may withdraw the consents for the marketing through the different means of communication from the user profile, where applicable, by de-selecting the relevant options. You can also withdraw consent for marketing via e-mail by selecting the appropriate link included at the bottom of every e-mail message received. Consent for profiling via cookies may be withdrawn by changing, at any time, the preferences of the user profile you can create on the Sites or Apps. Aside from the above means, you can always exercise your rights described above by sending a written request to ADJO at the following address: legal(At)adjo(Dot)cc. In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of personal information, if you believe that the processing of your personal information carried out through the Sites or Apps is unlawful.

Data Integrity and Security

We use reasonable and diligent efforts to maintain accurate information on our customers, and have adopted and implemented reasonable industry standard security procedures to protect any such information collected. We constantly monitor our systems, which are protected using industry-standard security measures. Although ADJO will use reasonable efforts to secure network communications and our Sites or Apps, we cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure.

Verification upon Accessing or Changing Personal Information

To protect customer privacy and security, we reserve the right to take reasonable steps to verify a customer's identity prior to granting access to or processing changes or corrections to such information. We will retain a customer's personal information for so long as its account is active or as reasonably needed by us to provide our Services. We may also retain and use such information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Revisions or Changes

ADJO reserves the right to change this Policy and other policies prospectively at any time, subject to applicable laws and regulations, by posting a prominent notice of any such material changes on the Site or App prior to the change becoming effective. Regardless of later updates or changes to our Policy, we will never use the information you submit under our current Policy in a new way without first providing you an opportunity to opt out or otherwise prevent such use.

HOW TO CONTACT US

General

If you have any questions or concerns about this Policy or the way your information is being used by ADJO, or should you wish to contact us for any other reason described in this Policy, you can contact us (i) by e-mail directed to legal(At)adjo(Dot)cc or (ii) by mail addressed to ADJO Digital DMCC, Box 430079, Dubai, UAE, attention Legal/Privacy Compliance.

Effective Date of Policy

This Policy was last updated as of the last date set forth above. If you would like to see an earlier version of this Policy, please contact us using one of the methods set forth above and specify the applicable date or time period for the prior Policy version requested.

© 2020 ADJO Digital DMCC. Any rights not expressly granted herein are reserved by ADJO.

ADJO is a registered trademark of ADJO Digital DMCC. IOS is a registered trademark of Apple Inc. Android is a trademark of Google Inc.