PRIVACY POLICY – ZAHARAMALL (by A2Z TRANSWORLD SERVICES LIMITED)
This Privacy Policy was developed by the Company to explain how we collect, process, apply, share, store and retain the personal data collected from you.

1. MODIFICATIONS TO THIS PRIVACY POLICY

From time to time, we may modify, revise and add specific instructions, policies and terms to this Privacy Policy. Any future updates to this Policy shall form part of this Privacy Policy. Whenever we make any material changes to this Privacy Policy, we will post the updated Privacy Policy and notify you via our periodic newsletters (if you are subscribed), or on this link or on our website or other means. Prior to giving consent, the Data Subject shall be informed of his right and method to withdraw his consent at any given time. However, the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

• WHAT INFORMATION DO WE PROCESS?

1. “Location Data”

We obtain this information from your GPS, IP address, device, WiFi, compass, IP address, or public posts that contain location information. You may also be required to disclose your location before you use any of our service functionalities or features or prevent fraudulent log-ins to your account and for account management purposes.

• “Personal Information”

These are information that relates to you and can be used whether directly or indirectly to identify you. They include the unique identifiers which have been assigned or chosen by you for the purpose of accessing our services or products.

• “Your Connections”

To help you organize how you communicate with others and maximize our service, we may create a favorites list from your purchase list, suggest groups and/or broadcast lists common to your purchase/activities, and such groups and lists get associated with your account information.

1. “Log Data”

These are information automatically collected from you when you use our products or services or website. They include technical information, such as your mobile carrier-related details, configuration information made available by your web browser or other programs you use to access any of our services or products, your IP address and your device’s version and identification number. Log data incudes Information about your communications on any of our chat platforms, such as the identity of a user that you have communicated with and the time, data and duration of your communications (excluding the content of such communications, unless the communication is done with any of our support services team).

• “Your Content”

These are information, either about you, relating to you or materials posted, that is voluntarily shared by you on any of our platforms while using our products or services. Shared Information may include postings or postings from other users which you repost, are accessible without your prior consent and Location Data and Log Data associated with such postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using services and platform share about you.
You remain responsible for your Content and we will not in any circumstance be liable for any claim, damages, loss, misrepresentation and any other event which may give rise to a liability as a result of your content shared on any of our platforms.
You agree that we and any other Company affiliated to us are authorized to retain and continue to use your Content after you cease using any of our services or platform or may be required to retain or disclose Your Content (a) in order to comply with applicable laws or regulations; (b) in order to comply with a court order, subpoena or other legal processes; (c) in order to respond to a lawful request by a government authority, law enforcement agency or similar body (whether of your jurisdiction or elsewhere); or (d) where we believe it is reasonably necessary to comply with applicable laws or regulations, in each case whether such applicable law or regulation, legal process or government body is that of your jurisdiction or elsewhere.

1. “Customer Support Information”

These are information which we obtain from your communication with our Customer to investigate your support issues.

• “Payment Card Details”

Depending on your country, credit or debit card information may be collected and the card information verified via a third-party payment processing service for verification purposes (such as for fraud, purpose of confirmation or verification of account liquidity). Additionally, your credit card number, expiry, CVC and cardholder name may be collected for the same purpose. We do not permanently store your card details in our environment but immediately dispose off the information as soon as verification has been concluded.

• “Product/Service Surveys”

These are periodic surveys which we may carry out in respect of our products or services, if you choose to participate in any of surveys, we may request certain Personal Information from you. We may use a third party service provider to conduct these surveys and this will be notified to you prior to your completing the survey.

• “Sensitive Information”

Depending on your Country, certain types of Personal Information, such as information about your race or ethnicity, origin, religious or philosophical views or personal health origin, religious or philosophical views or personal health. We must state that your Content that you share on any of our platforms, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others. It is advisable that you ascertain that there are no sensitive information in your Content before sharing them on any of our platforms.

1. HOW WE COLLECT YOUR DATA

We collect Personal Data from and about you when you register, use or process information on our platform or use our Products and Services, including the following:

1. Enrollment information – We collect certain personal information from you, (such as your name, username, password, gender, IP address, other registration data or other unique identifiers which may differ depending on the product or service being registered for).

• Transaction and User Experience information – By using our products, services or platform to make purchases from merchants, to make payments or chat with other users, we collect information about the transaction, service experience and other information related to these transactions amount spent, product or service paid for, merchant information, including information about any funding instruments used to complete the transaction and any other information which we deem necessary to improve user experience on our platforms.
• Personal data that you choose to provide us to obtain additional Services or specific online Services – If you request or participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection, if the use of that Personal Data differs from the uses disclosed in this Privacy Policy.
• Personal Data about you from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.

c) Other information related to our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a consumer or service survey.

• WHAT WE DO WITH YOUR DATA

We use the Data we collect to help us operate, provide, improve, understand, customize, support, and provide you with rich, interactive Customer experiences. In particular, your data is used for the following purposes:

1. Commercial Messaging – We will allow you and third parties on A2Z to communicate with each other using the provided services for business purposes, such as through service or merchandise orders, product and service sales, updates, and marketing.

• To verify your account and eligibility for any of our products and Services.
• To communicate with you through the channels you have approved to keep you up to date on our latest products and services, corporate and business announcements, and other information about our services, products and technologies – including client briefings, newsletters and other information.
• For compliance with our legal obligations such as record keeping obligations (such as under antitrust laws, export controls, trade sanction and embargo laws, for anti-money laundering, financial and credit check and fraud and crime prevention and detection purposes), which may include automated checks of your contact data or other information you provide about your identity against applicable sanctioned-party lists which may be relevant for compliance purposes.
• Personalize our products and make recommendations or to analyze and improve our services and communications, and to advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you with relevant offers.
• We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research to make the Service a better one for you and other users.

1. To protect the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and to detect security threats, fraud or other criminal or malicious activities.

• To monitor and assess compliance with our policies and standards;
• To identify persons authorized to trade on A2Z personally or on behalf of our clients, customers, suppliers and/or service providers.
• On instruction or request from a relevant law enforcement agency or body in any jurisdiction or a relevant Third Party Entity.
• Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.
• To comply with court orders and exercises, or when required by law to respond to legal process and/or defend our legal rights.

q) For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us.

• SHARING OF YOUR INFORMATION

We may share your personal data in the following circumstances:

1. We may share your personal data between A2Z entities and/or Merchants on a confidential basis where this is required for the purpose of providing you with our products and services, as well as for administrative, billing and other business purposes.

• We may disclose your contact details on a confidential basis to third parties for the purposes of collecting your feedback on our service provision, to help us measure our performance and to improve and promote our services.
• We may share your personal data with companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such personal data is shared.
• We may share your personal data with any third party to whom we assign or novate any of our rights or obligations.
• We may share your personal data with courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process.

c) We may also use aggregated personal data and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.

1. STORING YOUR INFORMATION

Be assured you that we take reasonable and practical steps and measures to secure the integrity of retained information. This we do by using best internationally and acceptable technological standards to prevent unauthorised access to or disclosure of your personal data, and protect your personal data from misuse, loss, alteration or destruction. Same level of security and integrity attached to our own information are deployed to safeguard your information.
Your personal data may be stored in data centres within and outside your country of residence. The infrastructure housing the data are owned and operated by us, our service providers or affiliated companies. Where the location that personal data is transferred to or stored does not have substantially similar laws as your local country of residence, we will take reasonably practicable steps to ensure that your personal data is adequately protected in that jurisdiction.

• SECURITY OF YOUR PERSONAL DATA

We take your privacy very seriously and work hard to protect your data from being accidentally lost, used or accessed in an unauthorised manner, way, altered or disclosed. We have put in place appropriate security measures to prevent this from happening. In addition, your personal data is only accessible by employees, volunteers, agents, contractors and other third parties strictly on a need to know basis for the purpose of providing the service and products. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

• WHY WE ARE RETAINING YOUR INFORMATION

Your personal Data is retained in recognizable and usable format generally for the period of time required by regulation and in compliance with all legal obligations and other business objectives. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. It is possible for us to retain your information for longer periods than required by law as long as this is not in contravention of any existing law or regulation, and there are valid reasons for us to retain such data beyond the stipulated period.

• MANAGING YOUR INFORMATION

If you would like to manage, change, limit, or delete your information, we allow you to do that through the services settings to manage certain information available to other users. You can manage your contacts, groups, and broadcast lists, or use our block feature to manage the users with whom you communicate. You may also delete Your account. You may delete your account at any time (including if you want to revoke your consent to our use of your information). Be mindful that if you only delete our Services from your device without using our in-app delete my account feature, your information may be stored with us for a longer period. Please remember that when you delete your account, it does not affect the information other users have relating to you, such as their copy of the messages you sent them.

1. ASSIGNMENT, CHANGE OF CONTROL, AND TRANSFER

All of our rights and obligations under our Privacy Policy are freely assignable by us to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your information to any of our affiliates, successor entities, or new owner.

• OUR GLOBAL OPERATIONS

You agree to our information practices, including the collection, use, processing, and sharing of your information as described in this Privacy Policy, as well as the transfer and processing of your information to the United States and other countries globally where we have or use facilities, service providers, or partners, regardless of where you use our Services. You acknowledge that the laws, regulations, and standards of the country in which your information is stored or processed may be different from those of your own country.

• Any Age restriction for accessing Our Services?

Our Site and Services are not directed to children under the age of 16 years. We will not under any circumstance knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. Where we become aware that we have inadvertently collected Personal Data from a child under the age of 16, we will promptly delete it, unless we are legally obligated to retain such data. Where you are considered a minor in your jurisdiction, your parents or legal guardians must agree to these terms both for themselves and on your behalf and we will extract a verifiable parental consent permitting your access to this platform and the collection, use or disclosure of your personal information. Parents can revoke their consent and ask that information about their children be deleted from our site’s database. When a parent revokes consent, we will automatically stop collecting, using or disclosing information from the child user. The site may end a user’s participation in an activity on the platform if the information it collected was necessary for participation in that activity.

• Contact Us

If you have questions about our Privacy Policy, please contact us – legal@zaharamall.com