Last updated: 25 January 2023

This privacy policy (“Privacy Policy”) describes the privacy practices of Nazgul Nejmi Trading LLC (“Company,” “we” or “us”).

Company receives, collects, stores and manages personal information according to the following Privacy Policy. “Personal Information” is information that relates to an identified or identifiable individual. Personal information is also known as personally identifiable information.  Company is committed to comply with data privacy laws, where applicable.  This Privacy Policy is made in accordance with applicable privacy regulations and GDPR.

By using our wearekobyko.com, and/or purchasing our products and services (jointly hereinafter referred to as the “Website”) and by clicking accept on the Privacy Policy checkbox, you agree to the terms and conditions of this Privacy Policy.

This Privacy Policy forms a binding agreement between Company and you, being our customer.

  1. Data Collected
    • Data that you voluntarily provide us with:

1.1.1      You may provide us with your Personal Information in a number of ways, including, without limitation, when you:

    • register on the Website;
    • order, or purchase our services;
    • use the Website;
    • fill out and submit a form or survey;
    • download any materials or content through the Website;
    • participate in a contest or promotion;
    • have previously provided us with Personal Information prior to this Privacy Policy or last updates coming into effect;
    • subscribe to our email list, and/or service updates;
    • request support;
    • contact us directly in person or via any medium, including but not limited to by mail, telephone, and commercial electronic messages;
    • communicate with us for any matters and interact with or browse the Website generally.

1.1.2      Personal Information that we may receive includes, but is not limited to:

  • contact information such as email address, first name, last name, shipping address, telephone number (at your discretion);
  • billing information, billing address, phone number;
  • more detailed contact preferences.

1.1.3      Company may receive this data from you when you manually enter or otherwise disclose such data, or we may receive such data from third parties. We may combine such data.

1.1.4      By providing us with your Personal Information, you consent to this data being collected, used, disclosed, transferred to the UAE, and stored by us, as described in this Privacy Policy.

  • Data that we collect automatically

We collect data from every visitor and customer of the Website, in particular, we automatically collect data about your visit to the Website, your usage of our services, and your browsing activities. This anonymized information may include IP address, browser type, browser language, cookies data, performance specifications of the customer’s hardware and software, date and time of access to the Website, other information about how you interacted with our Website and our services.

  • Data from your use of the Website

We may receive data about how and when you use the Website, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This data may include, for example, your IP address, time, date, browser used, and actions you have taken within the Website. This type of data helps us to improve our Website, services, and products for both you and for all of our customers.

  1. Use of the Data

2.1.      We only use your Personal Information for the following purposes:

2.1.1      to provide you with the products and services that you purchased;

2.1.2      to personalize your experience when using our services;

2.1.3      to promote products or services available from us;

2.1.4      to send you informational and promotional content that you may subscribe to or unsubscribe;

2.1.5      to send you notifications, including notifications on change of our Website as we shall consider appropriate;

2.1.6      to communicate with customers about our Website, products, services and provide customer care in response to their inquiries;

2.1.7      to enforce compliance with the applicable law, governmental or judicial orders;

2.1.8      to protect our rights and safety as well as rights and safety of our users and third parties;

2.1.9      to contact you via surveys to conduct research about your opinion of our products;

2.1.10    to provide information to representatives and advisors;

2.1.11    to prosecute and defend a court, arbitration, or similar legal proceeding;

2.1.12    to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements;

2.1.13    to provide, support, and improve the services and products we offer;

2.1.14    to provide suggestions about products that you may be interested in and which you may opt out;

2.1.15    to transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition.

  1. Minors

Minors and children under age of 13 (or other legal age of your country of residence) should not use our Website and Services. We do not knowingly and purposefully provide any Services to minors. If you access our Website and Services, you represent that you have the legal capacity to enter into a binding agreement. If you are under 18, we require that you inform a parent or guardian about our Privacy Policy as well as obtain their consent to use our Website and Services.

  1. Sharing of Data

4.1       We do not share Personal Information, unless:

4.1.1      Doing so is appropriate to carry out your own request, including sharing or giving access to your Personal Information to our service providers as described in Terms and Conditions;

4.1.2      We believe it is needed to enforce our Privacy Policy, or if it is required, requested or demanded by law or any regulation or order;

4.1.3      We believe it is needed to detect, prevent or address fraud, security or technical issues;

4.1.4      We otherwise protect our property, legal rights, or that of others.

4.2       Company is operated from the UAE. If you are visiting the Website from outside of the UAE, you agree to any processing of any Personal Information you provide us according to this Privacy Policy.

4.3       If you are visiting Website as a citizen or resident of EU or EEA, you agree to any processing of any Personal Information you provide us according to this Privacy Policy and GDPR (General Data Protection Regulation) according to Section 7 of this Privacy Policy. If you are visiting Website as a citizen or resident of EU or EEA and any terms of this Privacy Policy are not in compliance with section 7, section 7 shall prevail.

4.4       We do not share your Personal Information with third parties, except for our vendors and service providers, such as providers of delivering services, hosting services, cloud services, and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services without your prior written consent (including via email).

4.5       We employ and contract with people and other entities that perform certain tasks for us or on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order to provide Products or Services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.

 

  1. Safeguarding your Personal Information

5.1       The protection of your Personal Information is vital to us. We take commercially reasonable measures to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. These security measures include, but are not limited to, SSL certificate for HTTPS.

5.2       Our employees, contractors, and any business partners can access Personal Information on a need to know basis, and we direct them to comply with the confidentiality and use terms of this Privacy Policy. We use encryption for sensitive information and we test our system on a regular basis to ensure we comply with industry practices and standards. While we strive to use commercially reasonable means to protect your Personal Information, no method of transmission over the Internet, or method of electronic storage, is completely secure, and we cannot guarantee absolute security of any data.

5.3       You agree to protect the security of your login information and password and not to transfer such information to any third party. We will not be liable to you for the use of your account by any third party.

5.4       If you become aware of any unauthorized use of your account, you shall immediately notify us in writing.

5.5.      If we become aware of any leak of your Personal Information which may cause a significant effect and damage to you, we will notify you within 10 business days after such event.

  1. Your Rights

6.1       You have the right to request any of the following from us at any time in writing:

  • Request information on your Personal Information stored by us;
  • Request to correct your Personal Information stored by us if it is not accurate. In this case you shall provide relevant evidence to prove the inaccuracy of the existing data and accuracy of the new data;
  • Request to transfer your Personal Information to a third party. We may reject such request if it is known to us that the third party does not have implemented relevant information security measures;
  • Request restriction of processing your Personal Information;
  • Request to delete your Personal Information.

6.2      We may not be able or not have a right to comply with any of your requests if we are otherwise compelled or required by law, regulation, judicial or governmental process or if we have a legitimate interest to control your data as described under article 1(f) of GDPR.

6.3    If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

  1. GDPR

All necessary, reasonable and applicable rights and obligations determined under GDPR is granted to you for the purposes of this Privacy Policy together with the other terms of this Privacy Policy subject to section 4.3 hereunder.

 

  1. Changes to the Privacy Policy

We may amend this Privacy Policy from time to time. Use of the information we collect is subject to the Privacy Policy in effect at the time such information is used. If we make major changes in the way we collect or use information, we will notify you by posting an announcement on the Website or sending you an email.

  1. Data Retention

We retain your Personal Information in the UAE. We retain your Personal Information for as long as we need it to fulfil the purposes for which we originally collect it, except if required otherwise by law. When you place an order through the Website, we will retain your Personal Information for our records unless and until you ask us to erase this information.

  1. Contact

10.1 If you would like to make a complaint, please contact us by e-mail or by mail using the following details: customercare@wearekobyko.com

10.2 If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority.

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