سياسة الخصوصية



Introduction

This policy applies to your use of:

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:

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:

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:

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: 

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:

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: 

  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.

Description of categories of personal data

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.