Introduction

This policy applies to your use of:

·AnaMeen Version 1.0 mobile application software (App) hosted on Google play Store and Apple App Store once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

·Any of the services accessible through the App (Service). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children without proper parental consent. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

AL AHLI FOR FINANCIAL TECHNOLOGY is the controller and is responsible for your personal data (collectively referred to as [“Company”], “we”, “us” or “our” in this policy).

If you have any questions about this privacy policy or our privacy practices, please contact us using the details set out below.

Contact details

Our full details are:

·Full name of legal entity: Al AHLI FOR FINANCIAL TECHNOLOGY

·Email address: hello@anameen.me.

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 updated on 02 January 2020  It may change and if it does, these changes will be  , where appropriate, notified to when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

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

Third party links

Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact Data and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

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

·Identity Data.

·Contact Data.

·Financial Data.

·Employment Data

·Transaction Data.

·Device Data.

·Content Data.

·Profile Data.

·Audio and Video Data

·Usage Data.

·Marketing and Communications Data.

·Location Data

We explain these categories of data here.

We may 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 App 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 which will be used in accordance with this privacy policy.

Except as otherwise specified in this policy, 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 data).

How is your personal data collected?

We will collect and process the following data about you:

·Information you give us.

This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register an App, subscribe to any of our Services, search for an App or Service, and when you report a problem with our App, or our Services. If you contact us, we will keep a record of that correspondence.

·Information we collect about you and your device.

Each time you visit one of or use our Apps we will automatically collect personal data including Device, Content and Usage Data. [Location Data. We also use GPS technology or any other technologies to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

·Information we receive from other sources including third parties and publicly available sources.

We will receive personal data about you from various third parties and public sources including but not limited to the following:

·Device Data from the following parties:

analytics providers such as Google;

advertising networks; and

search information providers.

·Contact, Financial and Transaction Data from providers of financial, technical, payment and delivery services;

·Identity and Contact Data from data brokers or aggregators;

·Identity and Contact Data from publicly available sources

·Unique application numbers.

When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

How we use your personal data

We will only use your personal data when the law allows us to do so and for the verification of the AnaMeen account/profile . Most commonly we will use your personal data in the following circumstances:

·Where you have consented before the processing.

·Where we need to perform a contract we are about to enter or have entered with you.

·Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

·Where we need to comply with a legal or regulatory obligation.

See GLOSSARY: LAWFUL BASIS to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

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

Purposes for which we will use your personal data

Purpose/Activity Type of Data Lawful Basis for Processing
To install the App and register you as a new App user Identity
Contact
Financial
Device
Your consent
Necessary for our legitimate interests (to create a verified AnaMeen profile that you can use when applying for a service or requesting goods and/or services from the commercial entities that are registered for this service).
To process in-App purchases and deliver Services including managing payments and collecting money owed to us (if any) Identity Contact Financial Transaction Device Marketing and Communications Location Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us and to process requests from the user to grant third parties access to their data) Identity
Contact
Financial
Transaction
Device
Marketing and Communications
Location
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us and to process requests from the user to grant third parties access to their data)
To manage our relationship with you including notifying you of changes to the App or any Services Identity
Contact
Financial
Profile
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyses how customers use our products/ Services and to process requests from the user to grant third parties access to their data) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey Identity
Contact
Device
Profile
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing Identity
Contact
Device
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App
Identity
Contact
Device
Content
Profile
Usage
Marketing and Communications
Location
Consent
Necessary for our legitimate interests (to develop our products/Services and grow our business)

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • 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.

International transfers

Whenever we transfer your personal data out of Jordan, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts which provide an adequate level of protection for personal data.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield.

Please contact us if you want further information regarding transferring your personal data out of Jordan.

Data security

All information you provide to us is stored on our secure servers and/or encrypted on our private blockchain., you are responsible for keeping your user name and password confidential. We ask you not to share your username and/or password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil 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 in 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 unauthorised 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 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.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

  • 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 (if any) you and to check that we are lawfully processing it.
  • 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.
  • 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, however, 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.
  • 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.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • if you want us to establish the data’s accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • 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
    • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • 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 which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. You acknowledge and agree that if you withdraw your consent to access and process your personal data and to this privacy policy, we may not be able to provide certain products or services to you, and you will not be able to utilize the App for its intended purpose, and your account and profile may no longer be valid and we cannot verify your AnaMeen profile for consumption by third-party entities whom you wish to grant access to your AnaMeen record for any product/service you require. Under no circumstances will we be liable to you or to any person for any indirect, incidental, special, punitive, cover or consequential damages (including, without limitation, damages for lost profits, revenue, sales, goodwill, use of content, impact on business, business interruption, loss of anticipated savings, loss of business opportunity) resulting from withdrawing your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at hello@anameen.me.

Glossary

LAWFUL BASIS

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us or clear opt-out using the functionality within the App for revoking access to any of the third-party entities at any time.

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.

THIRD PARTIES

Internal third parties

Other companies in the AL AHLI FOR FINANCIAL TECHNOLOGY Group acting as joint controllers or processors and who are based in or outside Jordan and provide IT and system administration services and undertake leadership reporting.

External third parties

Service providers acting as processors based in or outside Jordan who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in who provide consultancy, banking, legal, insurance and accounting services.

Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances. Financial taxation, judicial authorities, state agencies.

DESCRIPTION OF CATEGORIES OF PERSONAL DATA

  • Identity Data: includes first name, father’s name, grandfather’s name, last name, maiden name, username or similar identifier, password, marital status, family member data, title, date of birth, gender, all data provided/printed visually on government-issued identification documents.
  • Contact Data: includes physical address, mailing address, utility bill data, delivery address, email address and telephone numbers.
  • Financial Data: includes bank account, payment card details, specimen signature data, sources of income data, banking-related data and FATCA data and Form W-9 or Form W-8BEN data.
  • Employment Data: includes employer name, employer address and Contact Data, job title, salary and/or income, and employment status and type of employment.
  • Transaction Data: includes details about payments to and from you and details of in-App purchases.
  • Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
  • Content Data: includes information stored on your Device, including login information, photos, videos or other digital content, check-ins, and any content provided to us using the App.
  • Profile Data: includes your username and password, any data and/or documents provided to us using the App, in-App purchase history, your interests, preferences, feedback and survey responses.
  • Audio and Video Data: includes Liveness verification in audio-video authentication and photographic, audio and video data.
  • Usage Data: includes details of your use of our App including, but not limited to, traffic data and other communication data, and account activity/actions made using the App.
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Location Data: includes your current location disclosed by GPS technology or any other technology, as well as your Contact Data.
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