PRIVACY POLICY

Effective Date: [April 17/2020]

This Privacy Policy sets out how Chaufr Holding Ltd. [“Chaufr”, We”, “Us” “Our”) collect, store and use information about you when you use or interact with our website, www.chaufrapp.com (our “Site”) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from April 17 2020.

Contents

  • Summary

  • Our details

  • Information we collect when you visit our website

  • Information we collect when you contact us

  • [Information we collect when you interact with our website]

  • [Information we collect when you place an order [on our website]]

  • How we collect or obtain information about you from third parties

  • Disclosure and additional uses of your information

  • How long we retain your information

  • How we secure your information

  • Your rights in relation to your information

  • Your right to object to the processing of your information for certain purposes

  • Changes to our Privacy Policy

  • Copyright, credit and logo

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

Data controller and Data Protection Officer: Raji Daou – [email protected]

 

  • How we collect or obtain information about you:

    • when you provide it to us (e.g. by contacting us using or contact form, placing an order on our website and emailing us directly,

    • from your use of our website, using cookies, and

    • information from third parties in order for us to determine your location.

 

  • Information we collect:

    • Name;

    • contact details;

    • payment information e.g. your credit or debit card details;

    • IP address;

    • information from cookies;

    • information about your computer or device (e.g. device and browser type);

    • information about how you use our website (e.g. which pages you have viewed;

    • the time when you view them and what you clicked on;

    • the geographical location from which you accessed our website (based on your IP address and/or Google’s location services mobile app).

 

  • How we use your information:

    • for administrative and business purposes (particularly to contact you

    • and process orders you place on our website;

    • to improve our business and website;

    • to fulfill our contractual obligations;

    • to advertise our goods and services;

    • to analyze your use of our website; and

    • in connection with our legal rights and obligations

 

  • Disclosure of your information to third parties:

    • only to the extent necessary to run our business;

    • to our service providers;

    • to fulfill any contracts we enter into with you; and

    • where required by law or to enforce our legal rights.

 

  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event):

    • Yes, we may sell information for marketing purposes.

  • How long we retain your information:

    • for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, the performance of a contract with you or our legitimate interests as a business) For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

 

  • How we secure your information:

    • using appropriate technical and organizational measures such as:

    • storing your information on secure servers;

    • encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology,]

    • [encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology; and

    • only granting access to your information where necessary.

 

  • Use of cookies:

    • We use cookies on our website in order to enhance the user experience.

  • Your rights in relation to your information:

    • to access your information and to receive information about its use

    • to have your information corrected and/or completed

    • to have your information deleted

    • to restrict the use of your information

    • to receive your information in a portable format

    • to object to the use of your information

    • to withdraw your consent to the use of your information

    • to complain to a supervisory authority

 

  • Sensitive personal information:

    • We do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. [Please do not submit sensitive personal information about you to us.]. Sensitive information can include information that is not widely known to the public such as religion or political beliefs.

 

Our details

The data controller in respect of our website is Raji Daou. You can contact the data controller by writing to in5 Tech, Dubai, UAE or sending an email to [email protected]

If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

 

Cookies

We use cookies and similar technologies on our Site, including cookies and web beacons.

Cookies are data files that are sent from a website to a browser to record information about users for various purposes.

You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org  for a detailed explanation on how cookies are used.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number, and the information contained in any signature block in your email).

 

Contact form

When you contact us using our contact form, we collect your first name, last name, and email address. We also collect any other information you provide to us when you complete the contact form. Please do not include sensitive, privileged, or confidential information in the contact form.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your inquiry.

 

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Registering on our website

When you register and create an account on our website, we collect the following information:

  • name,

  • email address,

  • IP address and any other information you provide to us when you complete the registration for

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on Chaufr.

Information we collect when you place an order for a chauffeur

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Information collected when you place an order for a chauffeur

Mandatory information

When you place an order for goods or services on our website, we collect:

  • Your name

  • Phone number

  • Email Address

  • Billing Address

  • Shipping Address

  • Company Name (if applicable); and

  • Payment information

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

The reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfill our obligations under the contract, including sending you receipts, chauffeur details, and order confirmations.

 

Processing your payment

When you place an order on our website you will need to make payment for the services you have ordered. In order to process your payment, we use a third-party payment processor such as Checkout.

The third-party payment processor you choose to process your payment collects, uses, and processes your information, including payment information, in accordance with their privacy policies.


Marketing communications

At the checkout, you will have the option of receiving marketing communications from us. 

 

Our goods and services

You can opt into receiving marketing communications from us in relation to our services by emailing us at [email protected] or using our contact form.

 

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties other than your location in order to ensure the mobile application operates effectively. The third parties from which we receive information about you will generally include Google and its affiliates.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details but will include any additional information about you which they provide to us.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

 

Disclosure of your information to service providers and marketers

We use a number of third parties to provide us with services that are necessary to run our business or to assist us with running or promoting our business.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering services from us.

We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email at [email protected] and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

 

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc.

Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymized basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

Transfer and storage of your information

Information collected by Google Analytics is stored outside the Abu Dhabi Global Market on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the UAE, see the section of this privacy policy below entitled Transfers of your information outside the Abu Dhabi Global Market.

 

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our:

  • Accountants;

  • Advisors;

  • Affiliates;

  • Business partners;

  • Independent contractors; and

  • Insurers.

Further information on each of these third parties is set out below.

Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for accounting purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing required returns and our end of year accounts.

Advisors

Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice. Our advisors are located globally.

Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example. Our affiliates can be car wash stations, the location service industry and detailing service providers. Affiliates will share information with us and we will share information with them where you have expressed an interest in our services. Our affiliates are located in Dubai.

 

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services that they provide whether independently from, or in connection with or own services.

Our business partners are in the detailing, cleaning, and chauffeur industry. Our business partners are located in Dubai.

 

Independent contractors

We may use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them to perform in relation to our business. Our independent contractors may be chauffeurs. Our chauffeurs are located in Dubai.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them for chauffeur purposes. Our insurers are located in Dubai and globally.

 

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a physical assault, fraud, or a cybercrime has been committed or if we receive threats or malicious communications towards us, our staff, our independent contractor, or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual or non-contractual (such as legal rights that we have under Dubai laws).

 

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any action related to indemnification, mediation, arbitration, or court resolution or similar process.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena

 

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

 

Retention periods

Server log information: we retain information on our server logs for three (3) months.

Order information: when you place an order for chauffeur services, we retain that information for one (1) year following the end of the financial year in which you placed your order.

Correspondence and inquiries: when you make an inquiry or correspond with us for any reason, whether by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your inquiry, and for a number of further month(s), after which point we will delete your information.

E-Newsletter: we retain the information you used to sign up for our Chaufr e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • [the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);

  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);

  • whether we have any legal basis to continue to process your information (such as your consent);

  • how valuable your information is (both now and in the future);

  • any relevant agreed industry practices on how long information should be retained;

  • the levels of risk, cost, and liability involved with us continuing to hold the information; and

  • how hard it is to ensure that the information can be kept up to date and accurate

How we secure your information

We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible;

  • using secure servers to store your information; and

  • verifying the identity of any individual who requests access to information prior to granting them access to information.

 

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website, or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

 

Contact form

Information you submit to us via our contact form is transferred outside the UAE and stored on our third-party hosting service, Cloudflare Inc. Their Privacy Policy can be found here: https://www.cloudflare.com/en-ca/privacypolicy/

 

Email

Information you submit to us by email is transferred outside the UAE and stored on our third-party email provider’s servers. Our third-party email provider is: Cloudflare, Inc located in the United States of America.

Safeguard(s) used: Cloudflare, Inc has self-certified its compliance with the U.S. Privacy Shield.

 

E-Newsletter

Information you submit to us when you sign up for our e-newsletter is transferred outside the Abu Dhabi Global Market and stored on our third-party mailing list provider’s servers. Our third-party mailing list provider is: Cloudflare, Inc.

 

Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the UAE.

Safeguard(s) used: Google has self-certified its compliance with the U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome.

 

 

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to in5 Tech, Dubai, UAE or sending an email to [email protected]:

  • to request access to your information and information related to our use and processing of your information;

  • to request the correction or deletion of your information;

  • to request that we restrict our use of your information;

  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file)

  • to object to the processing of your information for certain marketing purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain marketing purposes); and

  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

 

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to in5 Tech, Dubai, UAE or sending an email to [email protected]:

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests; and

  • to object to us using or processing your information for direct marketing purposes

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

 

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

 

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy

Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

 

Copyright, credit, and logo

This Privacy Policy is based on Law No. 40 of UAE Copyright Legislation.

The copyright in this Privacy Policy is either owned by or licensed to Chaufr and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Contacting us

Should you have any questions or concerns about our privacy policy, please contact us at the following address, with Attention to the Chaufr Privacy Officer:

3529, Level 35, Al Maqam Tower,

Abu Dhabi Global Market Square, Al Maryah Island,

Abu Dhabi, United Arab Emirates

OR

3529, Level 35, Al Maqam Tower,

ساحة سوق أبوظبي العالمية ، جزيرة المارية ،

ابوظبي، الامارات العربية المتحدة

Questions or comments

If you have questions or comments about this privacy policy, please email us at [email protected]

© 2019 Chaufr Holding Ltd. All Rights Reserved.