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This privacy policy (“Privacy Policy”) governs the processing of your personal data as part of your use of the Website MenaHub.com (the “Website”) and its associated services (hereinafter together referred to as “Services”). This processing is undertaken by Mena Hub Innovations Ltd. (“we”, “us”, “our”) in compliance with the Law No. 13 of 2016 Promulgating the Protection of the Privacy of Personal Data Law. By using the Website and Services, you acknowledge that you have read this Privacy Policy carefully and that you agree with it without reservation. We reserve the right to modify, change or amend the Privacy Policy at our own discretion and from time to time. Such modification change or amendment shall be communicated via the Website. Please note that as part of the Website and/or Services, especially those provided via the Website, we may use so-called cookies. Cookies are small text files that are stored on a device’s hard drive and contain certain information and sometimes personal data. For more information on the way we use cookies, refer to the section on cookies below.

What We Process

  1. When using the Website and Services, you consent to the collection of personal data pertaining to you. Such personal data include: When using the Website: technical information associated with the device you use, such as your IP address, browser type, geographical location and operating system; AND, OR; information concerning your browsing behaviour, such as how long you visit, what links you click on, what pages you visit and how many times you visit a page. When using our Services: your contact details and basic identities such as your name, e-mail address and country of residence; AND, OR; device-specific details which may be used to identify you When contacting us (via the Website, e-mail, telephone, social media channels, etc.): the basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, the company you work for, your function.;

  2. In principle, we obtain the above mentioned personal data directly from you. If, however, you choose to register via a social media account (e.g. Facebook or Google Plus), these data will be collected from your social media profile. We advise that you consult the privacy policy of your social media service provider to ascertain what data is processed by your social media service provider when you use the social media login feature. We will not send any of the personal data you provide via the Website to social media service providers unless you consent to it 

Why We Process Personal Data

  1. We may process your personal data to provide you in a personalized and efficient way with the information, products and services that you request, either via the Website, e-mail, telephone or social media channels.
  2. We may process your personal data for direct marketing purposes, i.e. to be able to provide you with targeted communications, promotions, offerings and other advertisements from us or our selected partners. Note, however, that we will obtain your prior consent before doing so11. You will have the right to opt-out of e-mail communications, using the link that is provided within the marketing e-mail.
  3. We may process your personal data to perform statistical analyses so that we may improve our Website and/or Services, or to develop new products and/or services.
  4. We may transfer your personal data to the financial institution or payment service provider to allow your financial institution and the payment service provider to comply with their legal obligations.
  5. We may process your personal data for informing any third party in the context of a possible merger with, acquisition from/by or demerger by that third party, even if that third party is located outside Qatar.
  6. If and when your registration with or use of our Website and/or Services can be considered (a) a violation of the terms or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Services, (c) a danger to the Website and/or Services or any of our or our subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal, we may process your personal data for the preservation of the legitimate interest of us, our partners or a third party.
  7. Your personal data may be transferred to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website and/or Services.

To Whom We Send Personal Data

  1. We do not send your personal data in an identifiable manner to any third party if this is not required to provide the Services to you, without your consent to do so.
  2. We may rely on third-party processors to provide you with the Services. We will ensure that third party processors are only allowed to process your personal data on behalf of us upon the instruction of us. We warrant that all third-party processors are selected with due care and are trained to be aware of the safety and integrity of your personal data.
  3. We may send anonymized and/or aggregated data to other organizations that may use those data for improving products and services as well as tailor the marketing, displaying and selling of those goods and services. 

Where We Process Personal Data

  1. We may transfer your personal data to organizations outside of Qatar. Should such transfer take place, we will ensure that there are appropriate safeguards in place to ensure the safety and integrity of your personal data as well as all rights with respect to personal data you might enjoy under applicable mandatory law

How We Process Personal Data

  1. We will process your personal data in a lawful, fair and transparent manner. We will do our utmost best to keep the personal data accurate and up to date.
  2. For processing your personal data under the conditions outlined in this Privacy Policy, we obtain your consent as a result of you using our Website and/or Services. We may also process your personal data for the preservation of the legitimate interests of us, our selected partners or a third party.
  3. We warrant that in case the processing includes personal data of a special nature such as the racial origin, children, health condition, physical conditions, psychological condition, religious beliefs, spousal relation, and/or criminal crimes, we have obtained the permission from the competent department within the Ministry of Transport and Communication as per the measures and controls decreed by the Minister of Transport and Communication.
  4. We do our utmost best to process only those personal data which are necessary to achieve the purposes listed in this Privacy Policy. Your personal data are only processed for as long as needed to achieve the purposes listed in this Privacy Policy or up until such time where you withdraw your consent for processing them14. Note that withdrawal of consent may imply that you can no longer use the whole or part of the Website and/or Services. We will delete your personal data if you delete/close your profile unless a legal or regulatory obligation or a judicial or administrative order prevents us to do so.
  5. We will take the appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access by our personnel or personnel of our third-party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are only best efforts obligations, which can never be guaranteed. In order to keep your personal data secure, we comply with the privacy policies established by the competent department within the Ministry of Transport and Communication.

Your Rights

  1. You have the right to request access to, as well as a copy of, all personal data processed by us pertaining to you. Subsequent requests for access addressed to us that are manifestly submitted for causing nuisance or harm to us, will not be dealt with. Please note that the provision of any copies may be subject to the payment of a reasonable administrative fee.
  2. You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. [In any case, you can correct a large part of these data yourself via your profile or account settings.] If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.
  3. You have the right to withdraw your earlier given consent for processing your personal data. Specifically for direct marketing e-mails that we send to you with commercial information and offers, you will have a possibility to opt-out (refuse) to receive such further e-mails by following a link that is provided within the e-mail.
  4. You have the right to request that personal data pertaining to you be deleted if they are no longer required in light of the purposes outlined in article 2 or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by us against legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
  5. You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with your particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.
  6. If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to [add e-mail address here, or perhaps some other contact method]. Such request should clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed and accompanied by a digitally scanned copy of your valid identity card proving your identity. We will promptly inform you of having received this request. If the request proves valid, we shall honour it as soon as reasonably possible and at the latest thirty (30) days after having received the request. If you are not satisfied with the outcome provided by us, you may file a complaint with the competent department within the Ministry of Transport and Communication. 

Cookies

  1. You can avoid cookies being placed by configuring your browser as such. Guidelines as to how to do this can be found here:

    Internet Explorer:
    http://windows.microsoft.com/en-gb/windows7/Block-enable-or-allow-cookies

    Microsoft Edge:
    http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq

    Chrome:
    https://support.google.com/chrome/answer/95647?hl=en

    Firefox:
    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

    Safari:
    https://support.apple.com/kb/PH19214?viewlocale=en_US&locale=nl_BE

    However, not allowing cookies when visiting the Website may cause certain or all features of the Website to stop working properly.

  2. You may at all times withdraw your consent with our use of cookies. To exercise this right, it suffices to delete the cookies which have been placed on your device. To do so, you are kindly asked to refer to the appropriate instructions of your browser manufacturer, as listed above.

 

 

Section A - Privacy Policy

This privacy policy is applicable in respect of your visit to and transactions over the website http://www.menahub.com/ (“Website”). This website is owned, operated, and managed by MenaHub Innovations Trading WLL.

We, MenaHub Innovations Trading WLL and our affiliated companies worldwide (collectively, "we”, and the terms “our” and “us” are used accordingly), respect privacy of personal information. We are committed to implement the necessary systems and process which (a) ensure an appropriate level of protection of personally identifiable information that a visitor, a user, a client, a beneficiary, or a partner (“you”) share with us through our Website, its applications, mobile applications and digital interactions (collectively, "Platform") or whose information we otherwise receive in connection with our products and services, and (b) which gives you control over your personally identifiable information with us. This Privacy Policy ("Policy") describes how we collect, use, disclose and transfer your personal information through the Platform. By accessing the Platform and/or by availing any of our products or services or by partnering with us, you agree to the terms of this Policy. This Policy will be updated from time-to-time. Please refer back regularly to keep yourself updated. This Policy is a part of and must be read along with the Terms of Use and the Cookie Policy.


For residents of the European Union: When we collect and use personal data (information) about you, we may be subject to the General Data Protection Regulation (‘GDPR’) of the European Union and be responsible as a ‘data controller’ for such personal data. In such a case, references to the GDPR will apply to your information with us.

For residents of California: When we collect and use personal information about you, we may be subject to the California Consumer Protection Act (CCPA) and responsible as a ‘business’ or ‘service provider’ for such personal data. In such a case, references to the CCPA will apply to your information with us.

CONTENTS
1. Data we collect or process and its purpose
2. How we use your information
3. How we use your details for audience profiling
4. Sharing Information
5. External links and Cookies
6. How we work with third parties
7. Retaining and storing your information
8. How can you control your data or information.
9. How long will we keep your information.
10. Your rights regarding your information with us
11. International transfers
12. California Consumer Privacy Act (CCPA)
13. Policy Change
14. Contact Us / Data Protection Officer / Grievance Officer

1. Data we collect or process and its purpose
• We may process data about your use of the Platform (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of your visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. In addition, we may use third-party analytics tracking services such as Google Analytics and Facebook Pixel. This usage data may be processed for the purposes of analysing the use of the Platform and our products and services in order to improve our performance metrices, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely monitoring and improving the Platform and our products and services.
• We may process your information included in your personal profile on the Platform (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of the Platform and services and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of the Platform and our products and services.
• We may process your personal data that are provided in the course of the use of our products and services (“service data”). The service data may include your name, address, telephone number, email address. The source of the service data is you. The service data may be processed for the purposes of providing our products and services, ensuring the security of the Platform and of our products and services, maintaining back-ups of our databases, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of the Platform and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
• We may process information that you post for publication on the Platform or through our products and services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering the Platform and our products and services. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of the Platform and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
• We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you and for and for communicating with you. The legal basis for this processing is your consent.
• We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications, promoting our products and services to customers, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of the Platform and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
• We may process information relating to transactions, including purchases of our products and services, that you enter into with us and/or through the Platform (“transaction data”). The transaction data may include your contact details, your banking details, your credit card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services, keeping proper records of those transactions, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
• We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters, and for communicating with you. The legal basis for this processing is your consent.
• We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The Platform will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of the Platform and business and communications with our business counterparts.

In addition to the specific purposes for which we may process your personal data set out in this Section, we may process any of your personal data identified in this Policy where necessary for:
• the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
• the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
• compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person.

2. How we use your information
We will only use your personal data in a fair and reasonable manner, and where we have a lawful reason to do so. We primarily use your information for the following purposes.

To provide products and services. We may use your information and share your information with third-party service providers to provide products and services to you. We may also use your information for the following purposes.
• To manage your access to the Platform, and to send you content via push notifications, newsletters, subscriptions, etc.
• To send you service notifications related to your product or service such as password resets and order confirmations.
• To manage customer service queries and complaints.
• To develop, deliver and improve our products and services.
• To manage your privacy preferences and to ensure you only receive communications that you have requested, which may include using your details to suppress you from communications.
• To send you administrative emails about your account, reminders for upcoming events, service changes, or new policies. These updates, changes and notifications are essential for the services that you have selected.
• To provide general location-based services (e.g., based on the region or country you are in), advertising or search results for our content.
• To detect and reduce fraud and harassment, including DDOS and other efforts.
• To prevent users from posting illegal, offensive or objectionable comments on the Platform.
• To run competitions, prize draws and promotions or if you agree to be a speaker or contributor at, or in, one of our events, projects or films. In these cases, you grant a global right to us to use your name, picture, likeness, voice, biographical information and statements, for advertising, trade, publicity and promotional purposes in all media now known or discovered afterwards and on the internet.

To deliver marketing and advertising. We need your consent to use your information for specific purposes - such as marketing, brand communication and personalised advertising. If you consent, we will use your information as follows:
• We may send you marketing communications through a range of channels including email and push notifications and you can opt out of these at any time.
• We may pass your information to third-parties who would like to contact you with information regarding their own products and services. Those parties are responsible for their use of your data and you should read their privacy policies carefully.
• We will ask you if you wish to opt-out of marketing when you first sign up to receive our products or services. You can opt out of email marketing by clicking the ‘unsubscribe’ link at the bottom of our emails. Do note that this opt out mechanism does not apply to important service notifications such as license expiry notifications, payment confirmations or where we have some other legal basis for contacting you.
• In order to deliver advertising and marketing messages that are relevant to you, we may use the information we have about you, to ensure that the advertising you see is of interest to you.

Research. We use information you share with us, or that we collect to conduct research, surveys, product testing, and troubleshooting to help us operate and improve our products and services.
Other uses of your information. Other than where we have sought your consent, we rely on two other individual bases to lawfully use your information. First, we need to use your information in certain ways to provide our products or services to you, in accordance with our contract with you. In this case, it is necessary for us to use your information so that we can deliver the products or services you have chosen. In certain cases, we may use your information where necessary to further our legitimate interests, where those legitimate interests are not overridden by your rights or interests, including:
• To measure customer and user response and engagement with our products and services such as online content, email newsletters and subscription offers. This may include sharing your information with third-parties who help us to analyse and measure these parameters.
• To ensure our products and the Platform are compatible with the browsers and operating systems used by you.
• To help us improve our customer and user experience and to support new product development.
• To enable us to solicit feedback through customer satisfaction surveys and market research questionnaires (for which we may share your information with third-party service providers engaged by us).
• To create audience profiles for personalised advertising, marketing or research and development on and off the Platform.
• To detect and reduce fraudulent activity and for other security related purposes such as to help us protect against harassment, DDOS, IP infringement, crime or other security issues.
• For any purpose required by contract, law or regulation and to verify information that we provide to third-parties for compliance and audit purposes.
• To the extent required for identity verification, government sanctions screening and due diligence checks.
• To establish, exercise or defend legal rights in connection with legal proceedings (including any prospective legal proceedings) and to seek professional or legal advice in relation to such legal proceedings.

You have the right to object to any of the above uses of your information, please contact us if you wish to do so. We will consider all objections reasonably, but there may be legal reasons where we deem that the use of your information is still appropriate. We are committed to explain our decision to you.

We do not store any account-related information or any payment instrument (including credit card) details. We are not liable for any loss or damage caused to you as a result of any disclosure (inadvertent or otherwise) of any information concerning your accounts (including third-party account) or payment instruments in the course of any transactions or payments made for any products and/or services by you through the Platform.

3. How we use your details for audience profiling
To enable us to personalise the content and advertising you see (including on social media), we may use your interaction and browsing behaviour or preferences (such as the pages to visit and the content you access on the Platform) to create audience profiles. This is to enable content and message personalisation, and in some cases, advertising to be delivered to you or a group of users (an audience) with similar interests to you. This can be done both on our site and on those of third-parties. Please see our Cookie Policy for more information. We may analyse your individual information to create a profile of your interests and preferences as a part of an audience. These insights are used to help us make marketing decisions so that we can ensure our messages are relevant to you. There are times we may use additional information available from external sources to help us do this effectively.

4. Sharing Information
• We may disclose your personal data to any of our employees, officers, and agents as long as such disclosure is reasonably necessary for the purposes, and on the legal bases, set out in this Policy.
• We may disclose your personal data to any member of our group of companies (this means our ultimate holding company and all its subsidiaries and joint venture partners) as long as such disclosure is reasonably necessary for the purposes, and on the legal bases, set out in this Policy.
• We may disclose your personal data to our insurers and professional advisers as long as such disclosure is reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
• We may disclose your personal data to our suppliers or subcontractors as long as such disclosure is reasonably necessary for providing services to you.
• Financial transactions relating to the Platform and Services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
• We may disclose your personal data to third-party suppliers of goods and services for the purpose of enabling them to contact you so that they can offer, market and sell to you the relevant goods and/or services.
• In the case where we go through a reorganisation process, we may share, sell, or transfer information about you in connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy. However, this Privacy Policy will apply to your personal information that is shared with or transferred to the new entity.
• In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. External links and Cookies
External links. This privacy policy only applies to our use of your data. Our services, products or the Platform may, from time to time, contain links to external websites. We are not responsible for the privacy policies or the content of such external websites and we recommend that you read the privacy policies on any external websites that you use. Similarly, if you are directed to the Platform from a third-party, then we are not responsible for the privacy policy or practices of the third party. We strongly recommend you read their privacy policy.

Cookies. Some of our web pages utilize "cookies" and other tracking technologies. A "cookie" is a small text file that may be used, for example, to collect information about web-site activity. Cookies may be created in your web browser when you visit any part of the Platform. Some cookies and other technologies may serve to recall Personal Information previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our site is accessed. Our use of cookies and other tracking technologies allows us to improve our Platform and the overall website experience. We may also analyse information that does not contain Personal Information for trends and statistics. You can find more information about the types of cookies that we, and certain third parties use, why we use them, and how to manage them in our Cookie Policy.

6. How we work with third parties
We pass information to third-parties. In some instances, we disclose personal information to third-parties when it is necessary to deliver a service or product, or to help us improve your experience with us, or when we are required to do so by contract or law. “Third-parties” include agents, subcontractors, sponsors and other associated organisations. We have in place contracts to ensure the information remains secure and limited in use, and if we do not have a legitimate business reason to pass on your information, we will ask you to give consent first. Some examples of when we share your information are below:
• When you make a payment on the Platform, your payment will be processed by a specialist payment processor to ensure a secure transaction. All payment processors used by us are compliant with required security standards.
• When we send you an email or a push notification, these are delivered by marketing platforms. As part of this service, certain information such as message opens, clicks and formatting are recorded to help deliver the best email experience.
• When we test and launch new products, services or offers, we may work with trusted third-parties to support us.
• We also employ third-parties to carry out statistical analyses and conduct surveys on our behalf, to support our advertising and content production efforts respectively.
• To enhance your profile with non-personal information.
• To enable third-parties such as advertisers or sponsors to contact you with information about their own products and services that may be of interest, only if you give explicit permission for us to do so.

Third parties who pass information to us. We may use technology like APIs and embeds to make information available to websites, apps, and others for their use, for example, selecting a proper agent for your preference, choosing a special gift of your choice, etc.

Our services sometimes use additional information such as telephone numbers or postcodes from third-parties (like list brokers, researchers or telemarketing agents, who have gathered this information lawfully) to help us to contact you with important service updates via phone or post or to help us make marketing decisions. This includes advertising (by ourselves or via advertising partners) to groups of people with particular interests. These third-parties may give us access to your personal information, if you have allowed them to do so. We may also work with third-parties to identify individuals who may be interested in our products and services or in some cases our sponsors / advertisers’ products and services. These third-parties may give us access to your personal information, if you have allowed them to do so. The collection, use, and disclosure of information by these third-parties are described in their own privacy policies, and consequently may differ from that set out in this Policy. We are not responsible for those third-party privacy policies, and you should ensure that you have read and understood all applicable privacy policies before proceeding.

7. Retaining and storing your information
Data Retention policy. We securely store your information, and hold it for as long as we need to in order to provide our products and services to you in accordance with (i) applicable law, or (ii) as long as is set out in any relevant contract you have with us. We review our retention periods for personal information regularly. If you have not interacted with us in any way, we will generally no longer hold your information after seven (7) years from its last use. We would only keep it for longer than this if we are required to by law or if we have a legitimate reason to do so. Sometimes, we may need to keep it for longer periods for reasons such as tax and other financial regulatory mandates.

Data Erasure Policy. If you request for us to no longer contact you, for example with marketing communications, we will retain the minimum amount of information about you so that we can ensure we remove you from any future communications. Please note that if you ask us to completely remove all information about you, and you subsequently use our products and services at a later date, we will no longer be able to recognise your previous request not to be contacted, which is why we would keep it and suppress it in line with industry standards.

Storing and transferring information internationally. As the internet is a global environment and we work with third-parties across the globe, collecting and using your personal information may involve the transfer of this information internationally. By using our products and services, you acknowledge and agree to your personal information being transferred in this way, including to jurisdictions outside Qatar. We will maintain strict policies to ensure all information that is transferred is done so safely and securely.

Keeping your information safe. We take information security seriously and have policies and procedures in place to ensure the information we hold on you remains safe. We limit who has access to your information and ensure that those who do are bound by contracts to keep your information confidential and safe.

Individuals under 18. We do not, intentionally or knowingly, process personal information of individuals under the age of 18. We will make every effort to delete any details of such users where a parent or guardian has informed us that these details have been collected. Where person below the age of 18 years use products or services in contravention of Privacy Policy and Terms, we shall not be held liable or responsible for any damage or injury suffered by such person. Further if you are under 18 years of age, you cannot buy or sell product in the site, neither you will use the services offer by the platform.

8. How can you control your data or information.
Access, Correction, Portability. You can access, correct, or modify the information you provided to us by editing your profile and adjusting your account settings by emailing details of your request at response@menahub.com.

Deleting your information/ withdrawing your consent. You can delete your information or withdraw your consent which you provided to us by emailing details of your request at response@menahub.com.

9. How long will we keep your information.
When you give us any personal information, we will generally let you know for how long we will hold the information. In other cases, we will hold your information only for as long as it is required for the performance of our obligations under our contract with you or under any applicable law.

10. Your rights regarding your information with us
You may exercise your rights which are available to data subjects in relation to your Personal Information which is being held or processed by us.

Rights under the GDPR. Under certain circumstances, you have the right to:
• 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.
• Request correction of the personal data that we hold about you. This enables you ask us to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us, in certain situations, 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 exercised your right to object to processing (see below).
• 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. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us, in certain circumstances, to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Data portability: This enables you to ask us, in certain circumstances, to provide you with the personal data you have provided to us in a structured, commonly used and machine-readable format or to transmit the personal data that you have provided to us to another party.
• Automated decision-making: The right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.
• Right to withdraw consent: In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officers (details provided in this Policy). Once we have received a notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legal basis for doing so.

Rights under the CCPA. If the processing of your personal information is subject to the CCPA, you are entitled to the rights listed below.
• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
• Request erasure of your personal data. This enables you to ask us, in certain situations, to delete or remove personal data unless our processing is specifically permitted under the CCPA.
• Right of disclosure for sale of data or use for business purpose. This enables you to ask us, in certain circumstances, to provide you with the categories personal data and third-parties we disclose for sale or business purposes.
• Data portability: This enables you to ask us, in certain circumstances, to provide you with the personal data you have provided to us in a structured, commonly used and machine-readable format or to transmit the personal data that you have provided to us to another party.
• Right to opt-out: This enables you to opt-out of the sale of your personal data by a business to other third-parties.
• Right to non-discrimination: This specifies that we will not discriminate against you in any way or under any circumstance for exercising your rights to your data under the CCPA.
• Right to withdraw consent: In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officers (details provided in this Policy). Once we have received a notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legal basis for doing so.
• Rights in general. We provide you the right to keep your Personal Information held by us accurate and up-to-date. You may do so by contacting our Data Protection Officer on the details provided in this Policy if you wish to (a) rectify, update or correct your Personal Information, (b) obtain confirmation on whether or not your Personal Information is processed by us, or (c) access your Personal Information.

Do note that if you exercise any of the above rights, we may need to request specific information from you to help us confirm your identity and to ascertain that you are entitled to make such a request. This is to ensure that your personal data is not disclosed to any person who is not authorised to receive it. For the exercise of certain rights, you may be required to approach the designated data protection officer. You may be charged a fee for the processing of your request, particularly in case of frivolous, excessive, or manifestly unfounded requests. Do note that your rights listed in this Policy are not absolute and are subject to limitations as per the applicable data protection laws.

11. International transfers
We and many of our third-parties service providers are based outside Qatar, so the processing of your personal data will involve a transfer of data outside Qatar. Whenever we transfer your personal data out of Qatar, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
• We will only transfer your personal data to countries that the Qatar have approved as providing an adequate level of protection for personal data by; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the Qatar.
• We use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place;
• We will only transfer your personal data to companies that have appropriate measures to data security; or
• We will only transfer your personal data to companies that comply with the GDPR.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

12. California Consumer Privacy Act (CCPA)
In addition to the rights documented elsewhere in this Privacy Policy, if you are a California Resident you have some additional rights under the CCPA. These include being informed of any of your personal data that has been “sold” (where sold for this purpose is defined below) and to opt out of the future selling of your personal data to third parties. Do note that we may share your details with selected third-parties, where you have opted in for us to do so, which is defined as a “sale” of data under the CCPA. You can opt out of the sale of personal data at any time by contacting us. To submit requests for information about any of your personal data which we have sold according to the CCPA, you can get in touch with us by any of the methods listed in the Contact Us section of this policy. If you are emailing us for a request, please indicate in the subject that it is a CCPA-related request.

13. Policy Change
This is the most current version of the Privacy Policy which governs our processing of your personal data/ information and we may revise this Privacy Policy from time to time as needed. If we do revise this Privacy Policy and make changes that are determined by us to be material, we will post the revised Privacy Policy, and it will be effective from the date of such posting.

14. Contact Us / Data Protection Officer / Grievance Officer
For the purposes of your data collected through the Platform, held by us, or processed by us, the data controller (under GDPR and other laws which use a similar concept). If you have questions about this Policy or about your personal information, or if you wish to exercise a right regarding your information, please connect with us at following details
• Email: response@menahub.com
• Contact No.: +974 3111 4248

 

Section B - Cookie Policy

This Cookie Policy (“Policy”) is a part of, and must be read along with, the Terms of Use and the Privacy Policy. Terms used but not defined in this Policy shall have the meanings ascribed to them in the Terms of Use and the Privacy Policy. This Policy applies to the Platform, any website, branded pages on third-party platforms (such as Facebook, LinkedIn, Twitter, and YouTube), and applications accessed or used through the Platform, etc. which are operated by us or on our behalf. By using the Platform, you consent to our use of cookies in accordance with this Policy. If you do not agree to our use of cookies, you should set your browser settings accordingly or terminate your use of the Platform. Disabling cookies may impact your user experience while on the Platform.

CONTENTS
1. About Cookies
2. How we use Cookies
3. Types of Cookies we use
4. How and when are Cookies delivered
5. Use of cookies for analytics
6. Third-party cookies
7. Controlling cookies
8. More information
9. Contact us

1. About Cookies
Cookies are small pieces of text stored by a website you visit in your browser and subsequently sent by your web browser in every request to the website. A cookie file is stored in your web browser and allows the concerned website or a third-party to recognize you and make your next visit easier more personalised. Cookies allow us to serve you better and more efficiently, and to personalize your experience on the Platform.

2. How we use Cookies
We use Cookies for the following purposes:
• Advertising. We use cookies to help us to display advertisements which are relevant to you.
• Analysis. We use cookies to help us to analyse the use and performance of our website and services.
• Authentication. We use cookies to identify you when you visit the Platform and as you navigate the Platform.
• Cookie consent. We use cookies to store your preferences in relation to the use of cookies more generally.
• Personalisation. We use cookies to store information about your preferences and to personalise the Platform for you.
• Preferences. We save your preferences for a personalised browsing experience.
• Security. We use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect the Platform generally. We use cookies to protect you against spam and abuse.
• Status. We use cookies to help us to determine if you are logged into the Platform.

3. Types of Cookies we use
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, that is, when the web browser is closed. We use both Session and Persistent Cookies for the purposes set out below:

Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide you with services available through the Platform and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services that you have asked for cannot be provided, and we use these cookies only to provide you with those services.

Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Platform.

Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices you make when you use the Platform, such as remembering your login details or language preferences. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Platform.

4. How and when are Cookies delivered
We use cookies across various areas of the Platform, such as on our website, mobile sites and mobile applications. Any browser visiting these areas will receive cookies from us which helps us identify you when you return. Web beacons, tags and scripts may be used in the Platform or in our emails to help us to deliver cookies. We may perform analysis based on the use of these technologies and generate reports on an individual and aggregated basis concerning parameters such as visit counts, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

5. Use of cookies for analytics
We may use web analytics services on the Platform, such as services provided by Google Analytics. These services to help us analyse how the Platform is being used by you and other visitors. Web analytics services use performance cookies to track customer’s interactions. For example, by using cookies, such a service can inform us which pages our users view, which pages are most popular, what time of day certain section of the Platform are most visited, whether a visitor has been to the Platform before, what website referred the visitor to the Platform, and other similar information. All of this information is anonymized. Web analytics services collect the information to evaluate your use of the Platform and, in certain cases, to assist in online marketing, etc.

6. Third-party cookies
Third parties (advertising networks and providers of external services like web traffic analysis services) may also use cookies on the Platform. The names of cookies, pixels and other technologies may change over time. We suggest that you review the respective privacy policies for these external services to help you understand what data these organisations hold about you and how they process such information.

7. Controlling cookies
Most browsers allow you to control cookies through their settings preferences. However, if you choose to turn off these cookies, you will still see advertising on the internet but it may not be tailored to your interests. It does not mean that you won't be served any advertisements whilst you are online. Whilst we have mentioned most of the third-parties involved in using targeting or advertising cookies in the preceding section, the list is not exhaustive and is subject to change. Therefore, even if you choose to turn off all the third-party cookies listed in section, you may still receive some tailored advertisements and recommendations.

There are a number of ways you can manage what cookies are set on your devices. Essential cookies, however, cannot be disabled. If you do not allow certain cookies to be installed, the website may not be accessible to you and/or the performance, features, or services of the website may be compromised. You can also manage this type of cookie in the privacy settings on the web browser you are using. Please note that if you use your browser settings to block all cookies you may not be able to access parts of our or others' websites. Please see below for more information. The browser settings for changing your cookies settings are usually found in the 'options' or 'preferences' menu of your internet browser. In order to understand these settings, the following links may be helpful.
• Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
• Opera: http://www.opera.com/help/tutorials/security/cookies/
• Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
• Safari: https://support.apple.com/kb/PH21411
• Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
Alternatively, you may use the 'Help' option in your internet browser for more details on managing cookies.

8. More information
• More information about cookies, including how to see what cookies have been set and how to manage and delete them, can be found on www.allaboutcookies.org.
• More information about opting out of receiving interest-based ads from other companies can be found at optout.aboutads.info and www.networkadvertising.org/choices. In addition, certain third-party advertising networks such as Facebook (pixels) and Google permit users to opt out of or customize preferences associated with your internet browsing. To learn more about this feature, please visit:
- Google: https://policies.google.com/privacy
- Facebook: https://developers.facebook.com/docs/privacy/

9. Contact us
This Website is owned and operated by MenaHub Innovations Trading WLL. You may reach us as under

-By email on response@menahub.com
-Contact No.: +974 3111 4248