Privacy policy

1. Terms and Definitions

For the purposes of this Privacy Policy, the following terms are used:

• Personal data: Any information relating to an identifiable natural person.
• Data processing: Any action or set of actions with data, including its collection, recording, storage, modification, use and deletion.
• Third-party services: Organizations or platforms that provide additional services to improve our services.

We collect data to make our services as convenient and useful as possible for you. This includes:

• Information provided by users: When you interact with us - register on our website or in the application, fill out forms, write to us or use our services - When you log in to our service, we receive data transmitted by the Telegram messenger, including your username and ID. We do not ask for additional data, such as email or phone number, but you can voluntarily provide your email for the convenience of communication and notifications.
• Data from public sources: We may use information available from publicly available resources, such as official registries, public profiles on social networks and open databases. We do this solely within the law and only for specific purposes.
• Information from our partners: Our partners may share with us the information necessary to provide you with the best services. For example, if you interact with one of our partners, they may share with us data about your application or order.
• Data from data providers (Data Manager): We work with trusted companies that help us manage data. They provide us with information that is used strictly within the framework of agreements and applicable laws.
• Technical data: We collect information about the device from which you access our website or use the application. This may include, but is not limited to, the type of device, operating system, IP address, unique device identifiers, browser or application version information, as well as Telegram language settings and account status.
• Cookies and similar technologies: We use cookies and other technologies to analyze your behavior on the website and in the application, as well as to improve their performance. For more information on how we use cookies, please read our Cookie Policy.
• Local data: We may collect data about your location if this is necessary to provide certain features or improve the quality of the service. You can always disable access to location data through your device settings.
• Feedback and interactions: If you leave feedback, participate in surveys, or communicate with our support team, we collect data to improve your experience and optimize our product.

2. What Data do We Collect?

3. What do We Use Your Data For?

We use your data with care and attention, and only for the following purposes:

• Providing and improving our services: Data helps us make our products and services as useful and convenient as possible for you. For example, it allows us to customize our website and app to your preferences or provide you with relevant offers.
• Fulfil our obligations: We process data to fulfil our agreements with you or our partners, such as processing orders, providing support or resolving service-related issues.
• Analysis and development: We analyse data to better understand your needs and improve the quality of our services. This includes analysing statistics on the use of our website and app, as well as your feedback.
• Compliance with the law: We may process data to comply with legal obligations or to protect our legitimate interests.
• Personalisation: We use data to provide you with content and offers that are most relevant to you.
• Security: Data helps us detect and prevent fraud, abuse of terms of use and other security threats.

Your data may also be used to send you information and marketing materials. If you do not want to receive such messages, you can always opt out by changing your notification settings in your profile, using the "Unsubscribe" function in emails, or by contacting us.

In addition, your data may be used anonymously for statistical or scientific research. Such research helps us better understand user needs and improve our services.

The processing of your personal data is based on the following legal bases:

• Consent through use: By using our website or app, you automatically agree to the processing of your data in accordance with this Privacy Policy. This includes processing data to provide services, improve user experience and comply with our obligations to you.
• Legitimate interests: We may process data to protect our legitimate interests (for example, to prevent fraud, improve security or resolve legal disputes).
• Legal obligations: We process data to comply with applicable laws (for example, tax or financial regulations).

4. Legal Basis for Data Processing

5. How do We Protect Your Data?

We understand how important it is to ensure the security of your data, and we make every effort to protect it. Here's what we do:

• Use modern technologies to protect information from unauthorized access, loss or modification. For example, all data is transmitted and stored in encrypted form.
• Limit access to your data only to those employees and partners who really need it to perform their tasks.
• Regularly check and improve our security systems to always meet the highest security standards.
• Ensure data protection in mobile applications, including encryption of information and the use of secure data transfer protocols.
• Conduct employee training to improve their competencies in data protection matters.

Our services are not intended for use by minors without the consent of their legal representatives. If we learn that data has been provided by a person under 18 without permission from a parent or guardian, we reserve the right to delete that data. We are not responsible for information provided by minors without permission.

6. Responsibility for Data Provided by Minors

7. International Data Transfer

We may transfer your data outside the United Arab Emirates for processing in other countries. In such cases, we ensure that the data is processed in accordance with international data protection standards, including ensuring its security and confidentiality.

We store your data only for as long as necessary to achieve the purposes of processing or to comply with legal requirements. After this period, the data is:

• Securely deleted from our systems.
• Anonymized for statistical or research purposes.

You have the right to request the deletion of your data at any time. To do so, please contact us using the contact details provided below. We undertake to delete information, except in cases required by law.

8. Conditions for Storing and Deleting Data

9. Procedure in Case of Data Security Breach

In the event of a data security breach, including leaks, theft, or unauthorized access, we will take the following actions:

• Immediately notify all affected users via email or in-app notifications.
• Conduct an internal investigation to determine the cause of the incident and prevent it from happening again.
• Report the breach to the relevant regulatory authorities within 72 hours of discovery.

Despite all measures taken to protect your data, we cannot guarantee absolute security of information when transmitting it via the Internet or mobile networks. By using our services, you acknowledge and accept that data transmission is at your own risk. We are not responsible for the actions of third parties who have illegally gained access to your data, if this occurred without our knowledge or violation of our established security standards.

10. Limitation of Company Liability

11. Notifications of Changes to the Privacy Policy

We reserve the right to update this Privacy Policy. All changes will come into effect upon publication of the updated version on our website and/or mobile application. If the changes affect your rights or obligations, we will notify you of them in advance.

We undertake to notify users of changes to this Privacy Policy. Notifications are provided via:

• Email specified during registration.
• Banners or pop-up notifications on our website or application.
• Telegram bot.

Changes will come into effect upon publication of the updated version. If you continue to use our services after the changes come into effect, this is considered your consent to the new version of the policy.

We may use third-party services for data storage, analytics, payment processing or other functions, and we integrate third-party services such as maps, payment systems and analytics to provide you with a full range of services. All third-party providers are required to comply with our privacy standards and data protection laws.

We may use automated systems to analyze your data and provide personalized offers. Such decisions are made based on your browsing behavior, preferences and other parameters. You can always ask for an explanation of the rationale behind such decisions or refuse their implementation.

We also cooperate with various external service providers, including cloud technology providers, analytics platforms and payment processing services. All interactions with these services are governed by contracts that ensure a high level of data protection. However, we are not responsible for the actions of third-party services that go beyond our contractual obligations.

Data received from our partners, data providers or other third parties is treated with the same security and privacy standards that apply to data provided directly by users. We store such information only within the framework of applicable laws and agreements concluded with these parties. The data is used exclusively for the provision of our services and is not transferred to third parties without your consent.

12. Use of Third-party Services

13. Intellectual Property Rights

We reserve the right to use anonymised and aggregated data obtained from processing your information for analytical, research or commercial purposes. This data does not allow you to be identified as an individual and is used solely to improve our services.

If you have any questions about the protection of your data or want to exercise your rights, you can contact our Data Protection Officer:

Email: __________
Phone: __________

If you have any complaints regarding data processing, you can contact our Data Protection Officer via the contact details provided. We undertake to review your complaint and provide a response within 30 working days.

14. Contact Details of the Data Protection Officer

At TargetGram, we deeply value your privacy and are committed to protecting your personal information. We understand how important it is for you to trust us, and we strive to be as transparent as possible about what data we collect, how we use it, and how we keep it secure. This Privacy Policy is based on international data protection standards, including the General Data Protection Regulation (GDPR), the UAE Personal Data Protection Law (PDPL) No. 45 of 2021, and other applicable laws and regulations.

Please take the time to review our Privacy Policy so that you feel comfortable using our services, both through the website and through the mobile application.

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