PRIVACY POLICY

Introduction

Welcome to Dobrh’s (www.dobrh.com) privacy policy. The Dobrh Platform (“Dobrh”, “us”, “we”, or “our”) is owned and operated by Cognifle Limited, which has the license number [000007139] and has its registered office at the Abu Dhabi Global Market.

Dobrh respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data, tell you about your privacy rights, and explain how the law protects you when you visit the Dobrh website, Dobrh mobile app, or any other Dobrh-related products that link to this policy (regardless of where you visit it from).

This privacy policy forms an integral part of our Terms and Conditions, available on [⦁].

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 Dobrh collects and processes your personal data through your use of Dobrh website or Dobrh mobile application, including any data you may provide when you sign up, purchase or sell any products, goods, or services.

This platform 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 fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

This privacy policy is issued on behalf of Dobrh. Cognifle is the owner and responsible for the platform. Third party advertisements and links to third party websites may appear on the platform, such ads and links are not owned or controlled by Dobrh. We are not responsible for the content of third-party websites, services, and advertisements.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

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 [March 2024].

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

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

1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified (either directly or indirectly). It does not include data where the identity has been removed (anonymous data).

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

• • 1. Identity Data: It includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
    2. Contact Data: It includes billing address, physical/delivery address, email address and telephone numbers.
    3. Financial Data: It includes bank account and payment card details.
    4. Transaction Data: It includes details about payments to and from you and other details of goods and services you have purchased from us.
    5. Technical Data: It includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
    6. Profile Data: It includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
    7. Usage Data: It captures user interactions, including clicks, browsing patterns, app usage, and relevant data related to user behavior.
    8. Marketing and Communications Data: This includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    9. Location: It includes your precise location.
    10. Diagnostic Data: It includes crash data, performance data, and other diagnostic information.

We also collect, use and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data that will be used in accordance with this privacy policy.^[1]

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.^[2]

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 we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

1. How is your Personal Data collected?

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

• • 1. Direct Interactions: You may give us your personal data by filling out forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
       1. request for goods or services;
       2. create an account on our website or app, or
       3. subscribe to our services.
    2. Automated Technologies or Interactions: As you interact with Dobrh website, Dobrh mobile app, or any other Dobrh-related products, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.^[3]
    3. Third Parties or Publicly Available Sources: We will receive personal data about you from various third parties and public sources as set out below.
    4. Technical Data: The following parties provide us with your Technical Data:
       1. analytics providers such as Google and
       2. advertising networks such as Meta ads, Facebook ads, Instagram ads, X ads, Google ads, and Microsoft ads.
    5. Contact, Financial, and Transaction Data: Data from technical, payment, and delivery providers.
    6. Identity and Contact Data: All identity and contact information is taken from publicly available sources.

1. How do we use your Personal Data?

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

• • 1. we need to perform the contract we are about to enter into or have entered into with you;
    2. it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights not to 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 we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your Personal Data

Below, in table format, we have set out a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified our Legitimate Interests where appropriate.

Note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.^[4]

Marketing

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

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view of what we think you may want or need or what may be of interest to you. This is how we decide which goods, 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 or purchased 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 for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages by contacting us anytime.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a goods/service purchase, goods/service experience or other transactions.

Cookies

A cookie is a small text file which is placed onto your device when you access our website. We use cookies and other online tracking devices to make your online experience more efficient and enjoyable. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose 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 explain the legal basis that allows us to do so.

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

1. Disclosures of your Personal Data

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

• • 1. third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy;
    2. any other third party if we are under a duty to disclose or share your personal data to comply with any legal obligation or to protect the rights, property and or safety of Dobrh, our personnel or others; and
    3. any other third party for the purposes of acting in accordance with the requirements of a court, regulator or government agency, for example complying with a search warrant or court order or acting in accordance with applicable law or regulation.

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

1. International Transfers

We may transfer to and store the data we collect about you in countries other than the country in which the data was originally collected. Those countries may not have the same data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this privacy policy and comply with applicable legal requirements, providing adequate protection for the transfer of data to countries outside the Abu Dhabi Global Market.

1. Data Security

We value your trust in providing us with your personal information, thus we strive to use commercially acceptable means of protecting it. Unfortunately, no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

1. Data Retention

How long will you use my personal data?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see Your Legal Rights at section 9 below for further information.

In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

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

1. Your Legal Rights

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

• • 1. 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 and to check that we are lawfully processing it;
    2. request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may 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 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 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 may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request;
    4. 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
    5. request restriction on processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
       1. where you want us to establish the data’s accuracy;
       2. where our use of the data is unlawful, but you do not want us to erase it;
       3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, or
       4. you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it;
    6. request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you and
    7. withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure 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 up our response.

Time limit to respond

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

1. Glossary

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

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

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

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