Privacy Policy

Introduction

This policy applies to your use of:

• Our Pillvery Application can be accessed via our mobile applications (Application) available at Apple App Store, Google Play, and Huawei AppGallery once you have downloaded a copy of the Application onto your mobile telephone or handheld device (Device).
• Our services are accessible through the Applications (Services). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The Applications are not intended for children and we do not knowingly collect data relating to children without proper parental consent. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Genoa for Technology & Consulting Services L.L.C. is the controller and is responsible for your personal data (collectively referred to as \"Company\", \"we\", \"us\" or \"our\" in this policy).

 If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: Genoa for Technology & Consulting Services L.L.C.
• Email address: legal@pillvery.com
• Postal address: 3rd Floor, building #7, Arar Street, Jabal Amman, Amman, Jordan.
• Telephone number: +962 79 200 40 38 

You have the right to make a complaint at any time to the competent supervisory authority. 

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. 

This version was activated on April 17th 2021. It may change and if it does, these changes will be posted in our Applications and, where appropriate, notified to you when you next open the Applications OR as always available by checking our policies under General then selecting About tab. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Applications.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you. 

Third party links

Our Applications may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location 

Please check these policies before you submit any personal data to these websites or use their services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data.
• Contact Data.
• Financial Data.
• Transaction Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.
• Location Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Application feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Applications, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Applications, subscribe to any of our Services, request our Applications’ Services, search for products on our Applications,  Applications’ data shared via social media functions, enter a competition, promotion or survey, and when you report a problem with the Applications or any of our Services. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit our Applications, we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
• Location Data. We also use GPS technology and other location technologies to determine your current location or the location of your delivery. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties (and public sources) as set out below:
• Device Data from the following parties:
• Analytics providers;
• Advertising networks and
• Search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
• Identity and Contact Data from data brokers or aggregators;
• Identity and Contact Data from publicly available sources; and

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the Applications and to remember your preferences. This helps us to provide you with a good experience when you use the Applications and also allows us to improve the Applications. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, please check our cookie policy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances: 

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

See Below “Lawful Basis” to find out more about the types of lawful basis that we will rely on to process your personal data. 

We will send you direct marketing communications by email, text, or in-App notifications, if we have your consent. You have the right to withdraw that consent at any time by contacting us. 

Purposes for which we will use your personal data

Purpose/activity	Type of data	Lawful basis for processing
To register you as a new user in our Applications	Identity Contact  Device	Your consent
To process in-Site purchases and deliver services including managing payments and collecting money owed to us	Identity  Contact  Financial  Transaction Device Marketing and Communications  Location	Your consent Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the Applications or any Services	Identity  Contact  Financial  Profile  Marketing and Communications	Your consent Necessary for our legitimate interests (to keep records updated and to analyze how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey	Identity Contact Device  Profile  Marketing and Communications	Your consent  Necessary for our legitimate interests (to analyze how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and the Applications including  troubleshooting, data analysis and system testing	Identity  Contact Device	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you  To make recommendations to you about goods or services which may interest you To measure and analyze the effectiveness of the advertising we serve you  To monitor trends so we can improve the Applications	Identity  Contact  Device  Content  Profile  Usage  Marketing and Communications  Location	Consent  Necessary for our legitimate interests (to develop our products/Services and grow our business)

International transfers

Whenever we transfer your personal data out of Jordan, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts which provide an adequate level of protection for personal data.

Please contact us if you want further information regarding transferring your personal data out of Jordan.

Data security

All information you provide to us is stored on secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way. 

We will collect and store personal data on your Device using [application data caches and browser web storage (including HTML5). 

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill 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.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

 In some circumstances you can ask us to delete your data: see “Your Legal rights” below for further information.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. 

Please click on the links below to find out more about these rights: 

• Request access to your personal data (commonly known as a \"data subject access request\"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you to be corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

1. If you want us to establish the data's accuracy;
2. Where our use of the data is unlawful but you do not want us to erase it;
3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Description of categories of personal data

• Identity Data: [first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender].
• Contact Data: [billing address, delivery address, email address and telephone numbers].
• Financial Data: [bank account and payment card details].
• Transaction Data: includes details about products or services purchased, date & time of purchases, payment type, payments to and from you and complete orders’ details such as delivery locations.
• Device Data: includes [the type of mobile device you use,] [a unique device identifier [(for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device)],] [mobile network information,] [your mobile operating system,] [the type of mobile browser you use,] [time zone setting,] [OTHER INFORMATION].
• Content Data: includes information stored on your Device, including [friends' lists,] [login information,] [photos, videos or other digital content,] [check-ins,] [OTHER INFORMATION].
• Profile Data: includes [your username and password, Applications’ order/purchase history, your interests, preferences, feedback and survey responses].
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, [traffic data [and other communication data],] whether this is required for our own billing purposes or otherwise [and the resources that you access].
• Marketing and Communications Data: includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
• Location Data: includes [your current location disclosed by GPS technology or other location technologies and delivery locations specified by you.

You can exercise any of these rights at any time by contacting us at legal@pillvery.com

Glossary

Lawful Basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us. 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.