Privacy Policy

This privacy policy (“Privacy Policy”) of Mazad W.L.L., a limited liability company established in the Kingdom of Bahrain under commercial registration no. 112006 with the following address, Office No. 2605, Building No. 316, Road No. 4609, Block No. 346, Manama, Bahrain (“Mazad”, “We”, “Our” or “Us”), is applicable to anyone who accesses, downloads, registers on or uses Our Platforms (as defined below), including, but not limited to: (i) business partners; (ii) service providers; (iii) vendors; (iv) customers; (v) bidders; (vi) auctioneers; (vii) sellers; (viii) purchasers; or (ix) any other recipients of Our services, (individually “You”, “Your”, or “User” and collectively, the “Users”).

This Privacy Policy sets out Your privacy rights, how the laws of Bahrain (“Applicable Law”) protect You, and how We collect, use, retain and/or disclose information that We derive about Our Users, including Users of Our Website: https://mazad.app (“Site”), and any individuals who download, register on or use Our mobile application(s) (the “App”) (together the “Platforms”).

For the avoidance of doubt by accessing, using, downloading, or registering on Our Platforms in accordance with any terms and conditions which govern such use (the “Terms”), You as a User agree to the terms of this Privacy Policy and acknowledge that Your personal data will be Processed (as defined below) by Us as set out in this Privacy Policy.

This Privacy Policy must be read together with the Terms and any other policy We publish on the Site from time to time (the “Policies”), including but not limited to Our Cookies Policy and Terms of Use. If You do not agree to the provisions of this Privacy Policy, You should stop using Our Platforms immediately.

Our Platforms provide a platform whereby Users may connect with sellers to purchase goods and services by way of an auction, direct sale or other means. We act as a ‘Data Controller’ of Your personal data under this Privacy Policy in accordance with the provisions of Bahrain’s Law No. (30) of 2018 Promulgating the Personal Data Protection Law as amended from time to time (“Personal Data Protection Law”).

If You have any questions about this Privacy Policy or any requests to exercise Your rights, please contact Us at [email protected]

We regularly review this Privacy Policy, therefore You are encouraged to revisit the Privacy Policy, accessible on or through Our Platforms, from time to time to review any amendments to it. If You do not agree to any amendments of this Privacy Policy, please stop using Our Platforms immediately.

For the purposes of this Privacy Policy, “Process” or “Processing” has the meaning given to that term under the Personal Data Protection Law. Terms and expressions included hereunder in the singular shall also mean the plural and vice versa.

We may Process different kinds of personal data about You which We have grouped together below. It is important that the personal data We hold about You is accurate and up-to-date. Please keep Us informed if Your personal data changes during Your use of Our Platforms.

· “Identity Data” includes first name, last name, marital status, title, date of birth, gender, national identification number(s), passport number(s), and where relevant, qualifications, credentials, work experience, skills and employment information authentication data (including passwords, challenge/response questions and answers, PINs), photographs, and signatures.

· “Sensitive Data” includes information and documents revealing (whether directly or indirectly) the User’s race, ethnic origin, political or philosophical opinions, religious belief, affiliation to any union(s), criminal record, or any information related to their health or sexual status.

· “Personal Content Data” includes documents and material Users upload, share or submit on or through Our Platforms.

· “Contact Data” includes address, billing address, email address and telephone number(s).

· “Financial Data” includes bank account(s) and payment card details.

· “Transaction Data” includes details about payments to and from You and other details regarding assets and/or services that You have purchased on or through the Platforms.

· “Technical Data” includes internet protocol (IP) address, unique device identifiers, cookies, Your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices You use to access Our Platforms.

· “Profile Data” includes the username and password of Your Account (as defined below), purchase history, Your interests, preferences, feedback and survey responses.

· “Usage Data” includes information about how You use the Platforms.

· “Marketing and Communications Data” includes Your preferences in receiving marketing from Us and Your communication preferences.

You may decide which information, if any, You would like to share with Us. You understand that some functions of the Platforms may be unavailable to You unless You provide Us with the necessary information.Where We need to collect required personal data under the Applicable Law or the Terms and You fail to provide the data when requested, We may have to limit, cancel or suspend Your use of the Platforms.

We use several methods to collect Your personal data including:

· Your direct interactions with Us and Your use of the Platforms, including without limitation when You: (i) access the Platforms; (ii) register an account on the Platforms (“Account”); (iii) contact Us and provide feedback; (iv) make purchases through the Platforms; (v) share and upload material on or through the Platforms; (vi) complete surveys and forms; and

· automated technologies or interactions during Your use of the Platforms, which includes Technical Data about Your device, browsing actions and patterns by using cookies, server logs and other similar technologies. We may also receive Technical Data about You if You visit other websites using Our cookies.

We will Process Your personal data in accordance with Applicable Law. Most commonly, We will Process Your personal data after We have obtained Your consent unless Processing Your personal data is necessary:

· for the performance of any agreement We are going to enter or have entered into with You including without limitation;

A. to create an account for Your use of the Platforms (“Account”);

B. for billing-purposes;

C. to facilitate and enable Services; and

D. to showcase available goods, assets and services;

· as a response to a request made by You pursuant to the Personal Data Protection Law;

· to protect Your vital interests;

· to comply with Our legal obligations under Applicable Law;

· to fulfil Our regulatory compliance obligations, including ‘Know Your Client’ (“KYC”) checks confirming and verifying Your identity (including by using credit reference agencies, and third-party service providers) screening against governmental entities, supranational bodies (including the European Union, the United Nations Security Council, the UK HM Treasury, the United Stated Department of Treasury) and/or law enforcement agency sanctions list as well as international sanctions lists and other legal restrictions;

· to comply with an order from a competent court or the Public Prosecution;

· where it is necessary for Our legitimate interests (or those of a third party to whom Your personal data is disclosed) without prejudice to Your fundamental rights and freedoms;

· to communicate with You about Your use of the Platforms and any changes to the Site, the App, the Terms, this Privacy Policy and/or Policies that may affect You; and/or

· to verify Your identity.

We may also process Your personal data or Your Sensitive Data for any other purpose or under any other circumstance permitted by the Personal Data Protection Law and any decision issued pursuant to it, or by Applicable Law.

You agree and consent to Our disclosure of Your personal data for the following purposes:

· to enforce, or review any breach of, the Terms, this Privacy Policy and/or any of the Policies;

· to comply with Applicable Law, Our regulatory obligations (including, but not limited to, Our anti-money laundering obligations and KYC obligations), or the order of any other competent court;

· to further Our legitimate business purposes; and/or

· to investigate, intercept, or impede any illegal activities, suspected fraud, situations involving potential threats to Our and/or third party’s safety and security.

You agree and consent to Our disclosure of Your personal data to:

· any relevant Governmental, legal, regulatory, or similar authorities;

· Our accountants, auditors, financial advisors, lawyers and other external professional advisors; and/or

· Our Service Providers (defined below), including but not limited to any external third party KYC verification Service Providers.

We may employ or engage third parties to: (i) perform tasks related to the Platforms and their functionality on Our behalf; or and/or (ii) provide audit, legal, operational or other services for Us or on Our behalf (“Service Providers”). These tasks include, but are not limited to, KYC verification services, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. Subject to confidentiality obligations imposed on the Service Providers pursuant to any agreement signed between them and Mazad, Mazad will share with the Service Providers, to the extent reasonable, Your personal data so that they are able to perform the services that they have been engaged to provide.

Under Applicable Law, You have a number of important rights which You may exercise, free of charge, which include Your right to:

· the fair Processing of Your personal data for legitimate, clear and defined purposes;

· access Your personal data;

· require Us to delete, correct or restrict (to the extent permitted by Applicable Law) Your personal data under certain circumstances;

· request certain information on Your personal data and the Processing of Your personal data;

· object to the Processing of Your personal data for direct marketing purposes;

· object, in certain circumstances, to Our Processing or continued Processing of Your personal data;

· withdraw Your consent to the Processing of Your personal data; and

· make a complaint against Us relating to Our Processing of Your personal data with the competent authority in Bahrain.

We may need to request specific information from You to help Us confirm Your identity and ensure Your right to access Your personal data (or to exercise any of Your other rights). This is a security measure to ensure that Your personal data is not disclosed to any unauthorized person. We may also contact You to ask You for further information in relation to Your request.

We will try to respond to all legitimate requests in a timely manner and in accordance with the timeframes set out under Applicable Law, if any, following Our receipt of Your request.

We may use Your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what We think You may want or need, or what may be of interest to You. This is how We decide which services and offers may be relevant for You. Accordingly, You may receive marketing communications from Us unless You have opted out of receiving such communication in accordance with this Paragraph 8. You can ask Us to stop sending You marketing communication by following the opt-out procedures available on the Platforms from time to time or by contacting Us.

Many of the Users and Service Providers We deal with are based outside of Bahrain. Accordingly, We may transfer Your personal data outside of Bahrain in accordance with the Personal Data Protection Law and the regulations issued pursuant to it, subject to the prior consent of the competent authority in Bahrain if required by the Personal Data Protection Law. You hereby expressly consent to the transfer of Your personal data to any jurisdiction outside of Bahrain if such transfer is deemed necessary or desirable by Us for the provision of the services, or to ensure the proper operation or functionality of Our Platforms.

We have put in place appropriate security measures to protect Your personal data in accordance with Applicable Law. Such security measures aim to prevent Your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We encrypt Your personal data, however no data security measures can guarantee full security.You should take preliminary steps to protect against unauthorized access to Your login information and password of Your Account by keeping them private. We are not responsible for any lost, stolen, or compromised passwords or for any unauthorized activity on Your Account. We are not responsible for any loss or misuse of Your personal data, that is not within Our commercially reasonable control.

We have put in place procedures to deal with any suspected personal data breach and will notify You and any relevant regulatory authority in Bahrain of such breach where We are legally required to do so.

We will only retain Your personal data for as long as reasonably necessary to fulfil the purposes We collected them for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements under Applicable Law.

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 or other legal proceedings to which Your personal data may be relevant.

Once the retention period of Your personal data as required or permitted under Applicable Law have lapsed, Your personal data may be retained by Us for a longer period for historical, statistical, or scientific use provided that such data is encrypted or kept in anonymous form in accordance with the Personal Data Protection Law.