PRIVACY POLICY

Introduction

Welcome to the privacy policy of KLAIM UAE (the Company).

The Company respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1.

Important information and who we are

Purpose of this Privacy Policy
This privacy policy aims to give you information on how the Company collects and processes yourpersonal data through your use of this website, including any data you may provide through thiswebsite when you purchase a product or service.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fairprocessing policy we may provide on specific occasions when we are collecting or processingpersonal data about you so that you are fully aware of how and why we are using your data. Thisprivacy policy supplements other notices and privacy policies and is not intended to override them.

Controller
The Company is the controller and is responsible for your personal data (collectively referred to as the Company , we, us or our in this privacy policy).[We have appointed a [data protection officer (DPO)][data privacy manager] who is responsible foroverseeing questions in relation to this privacy policy. If you have any questions about this privacypolicy, including any requests to exercise your legal rights, please contact the [DPO][data privacymanager] using the details set out below.]

Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our usin the following ways:

Full name of legal entity:KLAIM UAE
Email address:karim@klaim.ai
Postal address:Ivo Ribar Lola 196
Phone number:333555
If you are concerned about our handling of your personal information, you can lodge a complaintwith a privacy supervisory authority. In the European Economic Area, the relevant supervisoryauthority is the one in the country or territory where:
  1. you are resident;
  2. you work; or
  3. the alleged infringement took place.
A list of National Data Protection Authorities in the European Economic Area can be found here:http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

We would appreciate the chance to deal with your concerns before you approach the relevantprivacy supervisory authority, so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last reviewed and updated on 9 February 2021.1 It is important that the personal data we hold about you is accurate and current. Please keep usinformed if your personal data changes during your relationship with us.

Third-Party links
This website may include links to third party websites, plug-ins and applications. Clicking on thoselinks or enabling those connections may allow third parties to collect or share data about you. Wedo not control these third party websites and are not responsible for their privacy statements.When you leave our website, we encourage you to read the privacy policy of every website youvisit.

2.

The data we collect about you

Purpose of this Privacy Policy
Personal data, or personal information, means any information about an individual from which thatperson can be identified (either directly or indirectly). It does not include data where the identityhas been removed (anonymous data).

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

  1. Identity Data includes first name, maiden name, last name, username or similaridentifier, marital status, title, date of birth and gender;
  2. Contact Data includes billing address, delivery address, email address andtelephone numbers;
  3. Financial Data includes bank account and payment card details;
  4. Transaction Data includes details about payments to and from you and otherdetails of products and services you have purchased from us;
  5. Technical Data includes internet protocol (IP) address, your login data, browsertype and version, time zone setting and location, browser plug-in types andversions, operating system and platform, and other technology on the devices youuse to access this website;
  6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
  7. Usage Data includes information about how you use our website, products and services; and
  8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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

If you fail to provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you,and you fail to provide that data when requested, we may not be able to perform the contract wehave or are trying to enter into with you (for example, to provide you with goods or services). Inthis case, we may have to cancel a product or service you have with us, but we will notify you ifthis is the case at the time

3.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  1. Direct interactions. You may give us your personal data by filling in forms or bycorresponding with us by post, phone, email or otherwise.
  2. Automated technologies or interactions.As you interact with our website, wewill automatically collect Technical Data about your equipment, browsing actionsand patterns. We collect this personal data by using cookies, server logs and othersimilar technologies.
  3. Third parties or publicly available sources.We will receive personal dataabout you from various third parties as set out below.
  4. Technical Data from the following parties:
    (i)   analytics providers;
    (ii)  advertising networks; and
    (iii) search information providers.
  5. Contact, Financial and Transaction Data from providers of technical, paymentand delivery services.
  6. Identity and Contact Data from data brokers or aggregators.
  7. Identity and Contact Data from publicly available sources.
  8. [●].

4.

How we use your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use yourpersonal data where:

  1. we need to perform the contract we are about to enter into or have entered intowith you;
  2. it is necessary for our Legitimate Interests (or those of a third party) and yourinterests and fundamental rights do not override those interests; or
  3. we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although wewill get your consent before sending third party direct marketing communications to you via emailor text message. You have the right to withdraw consent to marketing at any time by contactingus.

We will only use your personal data when the law allows us to. Most commonly, we will use yourpersonal data where:

  1. we need to perform the contract we are about to enter into or have entered intowith you;
  2. it is necessary for our Legitimate Interests (or those of a third party) and yourinterests and fundamental rights do not override those interests; or
  3. we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although wewill get your consent before sending third party direct marketing communications to you via emailor text message. You have the right to withdraw consent to marketing at any time by contactingus.

Changes to the Privacy Policy and your duty to inform us of changes
We have set out below, in a table format, a description of all the ways we plan to use your personaldata and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on thespecific purpose for which we are using your data. Please contact us if you need details about thespecific legal ground we are relying on to process your personal data where more than one groundhas been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of Legitimate Interest
To register you as a new customer
  1. Identity
  2. Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our Legitimate Interests (to recover debts due to us)
To manage our relationship with you which will include:
  1. Notifying you about changes to our terms or privacy policy
  2. Asking you to leave a review or take a survey
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our Legitimate Interests (to recover debts due to us)
  3. Necessary for our Legitimate Interests (to keep our records updated and to study how customers use our products/services)
  4. Performance of a contract with you
To enable you to participate in a prize draw, competition or complete a survey
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our Legitimate Interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  1. Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  2. Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  1. Identity
  2. Contact
  3. Technical
  4. Profile
  5. Usage
  6. Marketing and Communications
Necessary for our Legitimate Interests (to develop our products/services and grow our business)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  1. Technical
  2. Usage
Necessary for our Legitimate Interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
  6. Marketing and Communications
Necessary for our Legitimate Interests (to develop our products/services and grow our business)

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly aroundmarketing and advertising.

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what wethink you may want or need, or what may be of interest to you. This is how we decide whichproducts, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us orpurchased from us and you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party formarketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contactingus at any time.

Cookies
A cookie is a small text file which is placed onto your device when you access our website. We usecookies and other online tracking devices to make your online experience more efficient andenjoyable. You can set your browser to refuse all or some browser cookies, or to alert you whenwebsites set or access cookies. If you disable or refuse cookies, please note that some parts of thiswebsite may become inaccessible or not function properly. For more information about the cookieswe use, please see our Cookie Notice [●].

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless wereasonably consider that we need to use it for another reason and that reason is compatible withthe original purpose. If you wish to get an explanation as to how the processing for the newpurpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we willexplain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, incompliance with the above rules, where this is required or permitted by law.

5.

Disclosures of your Personal Data

We may share your personal data with the parties set out below for the purposes set out in thetable above in thePurposes for which we will use your Personal Data section.

  1. Internal Third Parties;
  2. External Third Parties;
  3. third parties to whom we may choose to sell, transfer or merge parts of ourbusiness or our assets. Alternatively, we may seek to acquire other businesses ormerge with them. If a change happens to our business, then the new owners mayuse your personal data in the same way as set out in this privacy policy;
  4. any other third party if we are under a duty to disclose or share your personal datato comply with any legal obligation, or to protect the rights, property and or safetyof the Company, our personnel or others; and
  5. any other third party for the purposes of acting in accordance with therequirements of a court, regulator or government agency, for example complyingwith a search warrant or court order or acting in accordance with an applicable lawor regulation.

We require all third parties to respect the security of your personal data and to treat it inaccordance with the law. We do not allow our third party service providers to use your personaldata for their own purposes and only permit them to process your personal data for specifiedpurposes and in accordance with our instructions.

6.

International Transfers

We do not transfer your personal data outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protectionis afforded to it by ensuring at least one of the following safeguards is implemented

  1. we will only transfer your personal data to countries that have been deemed toprovide an adequate level of protection for personal data by the  European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
  2. where we use certain service providers, we may use specific contracts approved bythe European Commission which give personal data the same protection it has in Europe. For further details, see  European Commission: Model contracts forthe transfer of personal data to third countries;or
  3. where we use providers based in the US, we may transfer data to them if they arepart of the Privacy Shield which requires them to provide similar protection topersonal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us whentransferring your personal data out of the EEA.

7.

Data Security

We have put in place appropriate security measures to prevent your personal data from beingaccidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, welimit access to your personal data to those employees, agents, contractors and other third partieswho have a business need to know. They will only process your personal data on our instructionsand they are subject to a duty of confidentiality.

Unfortunately, no transmission of data over the internet is guaranteed to be completely secure. Itmay be possible for unauthorised third parties, to intercept or access transmissions or privatecommunications unlawfully. While we strive to protect your personal data, we cannot ensure orwarrant the security of any personal data you transmit to us. Any such transmission is done at yourown risk. If you believe that your interaction with us is no longer secure, please contact us.

We have put in place procedures to deal with any suspected personal data breach and will notifyyou and any applicable regulator of a breach where we are legally required to do so.

8.

Data Retention

How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes wecollected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting orreporting requirements. We may retain your personal data for a longer period in the event of acomplaint or if we reasonably believe there is a prospect of litigation in respect to our relationshipwith you.

To determine the appropriate retention period for personal data, we consider the amount, natureand sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosureof your personal data, the purposes for which we process your personal data and whether we canachieve those purposes through other means, and the applicable legal, regulatory, tax, accountingor other requirements.

In some circumstances you can ask us to delete your data: see Your Legal Rights at section 9below for further information.In some circumstances we will anonymise your personal data (so that it can no longer beassociated with you) for research or statistical purposes, in which case we may use this informationindefinitely without further notice to you.

Whilst we continue to process your personal data we will ensure that it is treated in accordancewith this privacy policy. Otherwise, we securely erase your information once it is no longer needed.

9.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to yourpersonal data. The various rights are not absolute and each is subject to certain exceptions orqualifications. We will grant your request only to the extent that it follows from our assessment ofyour request that we are allowed and required to do so under data protection laws. Nothing in thisprivacy policy is intended to provide you with rights beyond or in addition to your rights as a datasubject under data protection laws. You have the right to:

  1. request access  to your personal data (commonly known as a “data subjectaccess request”). This enables you to receive a copy of the personal data we holdabout you and to check that we are lawfully processing it;
  2. request correction  of the personal data that we hold about you. This enables youto have any incomplete or inaccurate data we hold about you corrected, though wemay need to verify the accuracy of the new data you provide to us;
  3. request erasure  of your personal data. This enables you to ask us to delete orremove personal data where there is no good reason for us continuing to processit. You also have the right to ask us to delete or remove your personal data whereyou 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 that we maynot always be able to comply with your request of erasure for specific legal reasonswhich will be notified to you, if applicable, at the time of your request;
  4. object to processing  Interest (or those of a third party) and there is something about your particularsituation which makes you want to object to processing on this ground as you feelit impacts on your fundamental rights and freedoms. You also have the right toobject where we are processing your personal data for direct marketing purposes.In some cases, we may demonstrate that we have compelling legitimate groundsto process your information which override your rights and freedoms;
  5. request restriction of processing   of your personal data. This enables you to askus to suspend the processing of your personal data in the following scenarios:
    (i)   where you want us to establish the data’s accuracy;
    (ii)  where our use of the data is unlawful but you do not want us to erase it;
    (iii) where you need us to hold the data even if we no longer require it as youneed it to establish, exercise or defend legal claims; or
    (iv) you have objected to our use of your data but we need to verify whetherwe have overriding legitimate grounds to use it;
  6. request the transfer   of your personal data to you or to a third party. We willprovide to you, or a third party you have chosen, your personal data in astructured, commonly used, machine-readable format. Note that this right onlyapplies to automated information which you initially provided consent for us to useor where we used the information to perform a contract with you; and
  7. withdraw consent at any timewhere we are relying on consent to process yourpersonal data. However, this will not affect the lawfulness of any processing carriedout before you withdraw your consent. If you withdraw your consent, we may notbe able to provide certain products or services to you. We will advise you if this isthe case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
You will not ordinarily have to pay a fee to access your personal data (or to exercise any of theother rights). However, we may charge a reasonable fee if your request is clearly unfounded,repetitive or excessive. Alternatively, we could refuse to comply with your request in thesecircumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensureyour right to access your personal data (or to exercise any of your other rights). This is a securitymeasure to ensure that personal data is not disclosed to any person who has no right to receive it.We may also contact you to ask you for further information in relation to your request to speed upour response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longerif your request is particularly complex or you have made a number of requests. In this case, we willnotify you and keep you updated.

10.

Glossary

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

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

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