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PRIVACY NOTICE

1. INTRODUCTION

Avrioc Technologies LLC (“we”, “us”, “our”), based in Abu Dhabi, UAE is a limited liability company and the ‘data controller’ in respect of your personal information. We are engaged in the business of creating, designing, deploying, maintaining, and operating Apps, Software, Games, and AI-model development in the UAE. We operate www.avrioc.com (“Site”) and our Products (including the applications themselves, their websites, services, and features, etcetera, collectively as “Avrioc Products”, “Apps”).

We understand the importance of protecting the personal information of the customers (“Customer”, “you”, “user”, “data subject”) of our products. This Privacy Notice sets out the basis on how any of your personal information that our products collect from you, or that you provide us, will be processed by us. Please read this Privacy Notice carefully so that you are familiar with our practices regarding your personal information, privacy, and security while using Avrioc and Avrioc Products.

Each of our products have their own privacy notice which can be accessed from the respective websites. For general queries, please use the “Contact us” section of the website, and for data privacy-related concerns, write to us at privacy@avrioc.com.

2. PURPOSE AND CONSENT

This Policy has been developed for purposes of compliance with the Federal Decree-Law No. 45 of 2021 on Personal Data Protection Law (PDPL) in the United Arab Emirates (UAE).

Without information about you, we may not be able to provide you with the Services or the support you request or require. By using or accessing our Platform and/or Services, you consent to this Policy and to the data processing purposes and practices stated in it. If you do not agree with the data processing purposes and practices stated in this Policy, you may choose to stop using our Platform. We periodically update this Privacy Notice, and we encourage you to review this time to time. This Policy explains:

• i. The types of Personal Data we collect about you;

• ii. How we use Personal Data about you;

• iii. Types of information we disclose to third parties and the types of such third parties; and

• iv. How we protect your Personal Data;

3. WHAT PERSONAL INFORMATION WE COLLECT

We collect the following categories of personal information:

• i. Name

• ii. Email address

• iii. Contact Number

• iv. Any information that you provide us including your resume by sending an email to career@avrioc.com in order to apply for jobs posted on our website.

• v. Any information that you provide us including business proposals by sending an email to info@avrioc.com for potential business opportunities.

• vi. Recordings of virtual interviews with candidates as a part of the hiring process (which auto deletes in 12 months)

4. MODE OF PERSONAL INFORMATION COLLECTION

1. Information you provide to us directly:
• When you visit our website and provide us with your details along with a message to contact you.
• When you send an email to us at info@avrioc.com with your query and any supporting documents.
• When you apply for open positions at the Careers page by filling up a form with required documents or sending an email to the provided email address - career@avrioc.com
• When you share your details with the recruitment team to review your profile for suitable job opportunities.
• When you share your details with Avrioc as a part of Request for Proposal (RFP).
• When you visit our office as a guest and share your basic details to maintain entry into guest register.
2. Information collected automatically:
• Technical Information: We collect technical information associated with your activity on our Platform and may include information related to your browser and operating system, IP address (the Internet address of your computer) unique device identifiers, and other information such as your device type.
• Site Preferences and Cookies: We collect information about your preferences to make your use of the Platform more productive through the use of cookies. Cookies are intended to make using our Platform easier by, among other things, saving your preferences for you. For details of how we use cookies for this purpose, please review Clause 9 of this Policy.
3. Information Collected from Third parties:
• We collect Personal Data from third party partners who have your consent to provide us this data, and if you have given us consent to collect such data. We will gather Personal Data from third parties and service providers who you have authorized to collect, process, and share your Personal Data.
• We also collect Personal Data from you indirectly, when you provide Personal Data to our authorised partner entities who will then share the Personal Data with us to enable you to access the Services provided through our Platform.

5. USING YOUR PERSONAL INFORMATION

We do not sell, exchange, or give to any other person your Personal Data, whether public or private, for any reason whatsoever, without your consent, other than for the express purpose of providing our Services to you.

• We collect, process, and use Personal Data about you for the following purposes:

1. To provide our Services to you;
2. To improve, personalize and facilitate your use of our Services;
3. To measure, customize, and enhance our Services, including the design, content, and functionality of our Platform, or to track and analyse trends and usage in connection with our Services;
4. To analyse use of our Services;
5. To communicate with you, including without limitation, to deliver the information and support your request, including technical notices, security alerts, and support and administrative messages, transaction, and Service messages, to resolve disputes, collect fees, and provide assistance for problems with our Services;
6. establish, exercise or defend legal claims, whether in court proceedings or in an administrative or out-of-court procedure for the protection and assertion of our legal rights, your legal rights, and the legal rights of others;
7. To comply with our obligations either required by law or by written agreements with third parties;
8. in order to: (i) protect our rights or property, or the security or integrity of our Services; (ii) enforce the terms of our Terms and Conditions or other applicable agreements or policies; (iii) verify your identity (e.g., some of the government-issued identification numbers we collect are used for this purpose); (iv) investigate, detect, and prevent fraud, security breaches, and other potentially prohibited or illegal activities; (v) comply with any applicable law, regulation, or legal process.

We may use third-party service providers to process your Personal Data in the United Arab Emirates (UAE) and other countries. We ensure that the processing of Personal Data by such third parties will be based on legitimate legal grounds and will be performed in accordance with lawful instructions of the Company and in compliance with the PDPL and other legal requirements.

6. LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

The legal basis may differ depending on applicable local laws but generally we consider that our legitimate interests justify the processing. Our legitimate interests may include various business purposes, such as improving our services, developing new features, conducting research and analysis, providing requested services to you, ensuring the security of our systems, and promoting our business. When relying on these legitimate interests, we carefully consider the impact on your privacy rights and only proceed with processing if it is reasonably expected and does not unduly infringe on your rights and freedoms.

7. HOW LONG WE STORE YOUR PERSONAL INFORMATION

We use appropriate technical, organizational, and administrative security measures to protect any information we hold in our records from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. Recording of virtual interviews conducted as part of hiring process are retained only for 12 months.

We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim. Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent by writing to us at privacy@avrioc.com and request for deletion, then we will delete your personal information.

This Section Pertains to Users in the UK and/or the EEA

The personal information we collect may be transferred to, and stored at, a destination outside the EEA or the UK, including countries that have less strict or no data protection laws compared to those in the EEA or the UK. Whenever we transfer your information in this manner, we will take steps that are reasonably necessary to ensure adequate safeguards are in place to protect your personal information and to ensure it is treated securely and in accordance with this Privacy Notice. When relevant, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country.

If you are situated in the UK or the EEA, you can reach out to us at privacy@avrioc.com to request a copy of the safeguards we have implemented to protect your personal information and privacy rights under these circumstances.

We neither permit nor encourage the use of the website by children under the age of 16, and we do not knowingly collect personal information about children under 16. In essence, we do not intentionally store any personal information of any minor, and if you become aware that someone under the age of 16 has unlawfully provided us with personal data, please reach out to us, and we will promptly take measures to delete such information.  For specific controls on use of children’s personal information by our Products, please refer to their respective websites and Privacy Notices.

8. PERSONAL INFORMATION OF CHILDREN

We neither permit nor encourage the use of the website by children under the age of 16, and we do not knowingly collect personal information about children under 16. In essence, we do not intentionally store any personal information of any minor, and if you become aware that someone under the age of 16 has unlawfully provided us with personal data, please reach out to us, and we will promptly take measures to delete such information. For specific controls on use of the personal information of children by our Products, please refer to their respective websites and Privacy Notices.

9. COOKIE POLICY

This Clause of the Privacy Policy explains what cookies are, what information we collect using cookies and how we use cookies in respect of the Platform.

1. What is a cookie?
   • A ‘cookie’ is a small piece of encrypted text saved on the browser or hard drive in your computer or mobile device when you visit a website. Cookies are selected pieces of information that websites or mobile applications send to your device or computer’s hard drive, while you are viewing or using our Platform, as permissioned. It allows us to recognise you and make your next visit easier and the experience of our Services more useful to you. cookies can be stored for varying lengths of time on your browser or device.
   • We use both session / transient cookies (which expire once you close your device web browser) and persistent cookies (which stay on your device until you delete them) to collect information to provide you with a more personalized and interactive experience in using our Platform and Services. This type of data is collected to make our Services more useful to you and to tailor your experience with us to meet your special interests and needs.
2. How we use cookies
   • When you use and access our Platform, we may place a number of cookie files on your device’s web browser. We use cookies to enable certain functions of the Platform, i.e., to provide analytics, to prevent fraudulent or illegal activity, to store your preferences, to enable advertisements delivery, including behavioural advertising. We also use cookies to enhance your browsing experience by:
     1. Recognizing when you log in and any preferred settings
     2. Giving you a browsing experience that is unique to you and to serve you content which we believe improves your sites experience.
     3. Analysing how you use our sites which helps us to troubleshoot any problems and to monitor our own performance.
   • In addition to our own cookies, we may also use various third parties’ cookies to report usage statistics of our sites, deliver advertisements on and through our Platform, and so on.
3. Types of cookies we use

   We use the following four type of cookies:

   • Essential cookies:These cookies are essential to let you move around the Platform and use its features. These cookies allow our Platform to provide Services at your request. We use essential cookies to authenticate users and prevent fraudulent use of user accounts.
   • Performance cookies: These cookies may be used to collect information about how you use the Platform, e.g., what Services you are selecting and if you experience any error messages. They also allow us to update our Platform to improve performance and tailor it to your preferences. These cookies do not collect any information that could identify you - all the information collected is anonymous.
   • Functionality cookies: These cookies are used to remember the choices you make, e.g. your username, log in details and language preferences. They also remember any customizations you make to give you enhanced, more personal features of your digital experience.
   • Advertising and targeting cookies: These cookies are used to collect information about your visit to our sites, the content you viewed, browsing habits to deliver adverts which are more relevant to your interest, links you followed and information about your browser, device, and your IP address. They also measure the effectiveness of advertising campaigns.

Cookies preferences

Please note, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer on our Platform. You may not be able to store your preferences, and some of our pages might not display properly. The Company is not responsible and will not be held liable for any loss resulting from your decision or inability to use cookies.

10. INFORMATION SHARING AND DISCLOSURE

Avrioc does not share personal information about you with affiliates, partners, service providers, group entities and non-affiliated companies except: (a) to provide products or services you have requested; (b) when we have your permission: or (c) under the following circumstances:

1. We may share information with affiliated entities, subsidiaries, or branch offices for legitimate business purposes.
2. We may provide the information to trusted entities who work on behalf of, or with Avrioc, under strict confidentiality agreements. However, these companies do not have any independent right to further share or disseminate this information.
3. We may share information with statutory authorities, government institutions, law enforcement agencies or other bodies where required for compliance with legal requirements.
4. We may use the information to respond to subpoenas, court orders, or legal processes, or to establish or exercise our legal rights or defend against legal claims.
5. We may share information where we believe it is necessary in order to investigate, prevent, or take action against any illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
6. We may share information where we believe it is necessary in order to protect or enforce Avrioc’s rights, usage terms, intellectual or physical property or for safety of Avrioc or associated parties.
7. 7. We may share information about you if Avrioc is acquired by or merged with another company after ensuring such company offers equivalent level of protection for personal data.

11. SECURITY MEASURES

Avrioc is committed to safeguarding and protecting personal information and will implement and maintain appropriate technical and organizational measures to ensure a level of security appropriate to protect any personal information provided to us from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal information transmitted, stored, or otherwise processed.

Our website from time to time, contains links to our Product websites. If you follow a link to any of these websites and/or services, please note that they have their own privacy notices and we do not accept any responsibility or liability for them. For specific controls on how your personal information is processed, by our Products, please refer to their respective available on their websites or App.

12. YOUR RIGHTS AND CONTROLS

You have certain rights in relation to the personal data we hold about you as described below.

1. Right to access to Information
   • The categories of Personal Data processed;
   • The purpose of the processing;
   • Automated decision making on your Personal Data;
   • Target sectors or enterprises with whom your Personal Data is shared;
   • Controls or standards relating to storage of your Personal Data;
   • Actions for rectification, restriction, or erasure of your Personal Data which have been taken upon your request;
   • Safeguards in case of cross border Personal Data transfer;
   • Actions to be taken in case of personal data breach where such breach affects you; and
   • Procedure to lodge a complaint with the UAE Data Office.

We may refuse your demand if request is excessively repeated, is in contravention of judicial proceeding or investigations, negatively impacts our endeavours to maintain information security, or relates to the privacy of a third party.

2. Right to rectification
   • You have the right to rectify any inaccurate Personal Data about you and to complete any incomplete Personal Data about you.
3. Right to erasure

   You have the right to demand erasure of your Personal Data with us if:

   • the Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
   • you withdraw consent to consent-based processing;
   • you object to the processing of your Personal Data under the applicable law;
   • your Personal Data has been unlawfully processed; and
   • your Personal Data must be erased for compliance with legislation.

   We may refuse your demand if your Personal Data is processed for compliance with a legal obligation, or establishment or exercise or defense of legal claims.

4. Right to restrict processing

   You have the right to restrict processing of your Personal Data if:

   • you contest the accuracy of the Personal Data;
   • processing is unlawful;
   • we no longer need the Personal Data for the purposes of our processing, but you require Personal Data for the establishment, exercise, or defence of legal claims; and
   • you have objected to processing, pending the verification of that objection, in which case we may continue to store your Personal Data, but we will only otherwise process it: (i) where aforementioned processing is restricted only to storage of said Personal Data; (ii) with your consent; (iii) for the establishment, exercise or defence of legal claims; (iv) for the protection of the rights of another natural or legal person; or (v) for reasons of important public interest.
5. Right to stop processing

   You have the right to object to our processing of your Personal Data and stop the processing of said Personal Data in the following cases:

   • if such processing was done for direct marketing purposes;
   • if such processing was done for statistical survey purposes, unless such processing is necessary for public interest; and
   • where such processing is in contravention of personal data protection controls as envisaged by the PDPL and mentioned under Clause 4 (Personal data protection principles).
6. Right to Personal Data portability

   You have the right to Personal Data portability to the extent that:

   • the legal basis for our processing of your Personal Data is your consent, or is a necessity to perform a contract to which you are party; or
   • such processing is carried out by automated means.

   You have the right to receive your Personal Data from us in a structured, commonly used and machine- readable format. Where technically feasible, you may also request us to transmit your Personal Data directly to another entity.

7. Right to object to automated decision making

   You have the right to object to automated decision making (if any) if it has legal or serious consequences that affect you. Such requests may be refused by us if such automated processing is performed in accordance with any contract between you and us, is necessary for compliance with other legislation, or you have specifically provided consent for such practices.

8. Right to lodge a complaint with the supervisory authority

   In the UAE, you have the right to lodge a complaint with the UAE Data Office (if you have UAE domicile or place of business) or the Consumer Protection Department at CBUAE.

13. SUBMISSION OF REQUEST TO EXCERSIE OF RIGHTS

To exercise any of your rights, please contact us at privacy@avrioc.com. Please note that before responding to any requests to exercise your rights, we will require you to provide us with proof of identity and your address. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended in certain circumstances with prior notification to the requestor).

14. CHANGES TO THIS PRIVACY NOTICE

We may change this Privacy Notice at any time. The new Privacy Notice will be displayed on our website. The date this Privacy Notice was last updated appears at the top.