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Effective (August 15, 2022)

The Privacy Policy was updated on August 15, 2022. The protection of your privacy is a top priority for us at ZainTech. As we are committed to protect our customers’ information, we consider it important to be transparent by providing details on what data we collect, what it is used for, and how we safeguard your privacy and interests. This policy explains how we use your information and how we keep it safe.

Applicability of This Policy

This Privacy Policy is applicable to personally identifiable information (hereinafter referred to as “Personal Data” and detailed below) collected, processed, stored and used when you visit our website, use our services, or otherwise interact with us during the course of our relationship.

Acceptance of The Terms of This Policy

By using the services of the ZainTech, you agree to our terms of processing your Personal Data which you provide to us in accordance with this policy. In some cases, particularly if you reside in a country which is governed by a data protection regulation, we may ask you to provide consent for you to access our services. Please also note that our site contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. Privacy choices you may have made on third-party sites or platform will not apply to us or our use of Personal Data. We encourage you to be aware of the privacy practices of other sites that may collect your Personal Data.

How we define “Personal Data”

Personal Data is any data that can be used by itself to uniquely identify, contact, or locate a person, or can be used with information available from other sources to uniquely identify an individual.

Collection of Personal Data

When you use/ subscribe to ZainTech services, visit our website or interact with us through various channels such as purchases, account registrations, interact with customer care, through calls or chats or online forms, we may collect a variety of information.

Below are three ways in which we collect this information.

  • You provide us: with the required information when availing our services or directly communicate with us.
  • Online Forms: When you contact us or provide feedback using online forms, at minimum you may be required to provide us with name, email address and category of interest. Such information will be used to respond to your questions, comments, or requests by either ZainTech or any of its business divisions and subsidiary companies only.
  • Surveys: As with any regular survey, our online web surveys are there to help gather specific information regarding website issues. This helps to enhance the quality of service, which eventually will be reflected positively for our customers, given that the provision of their name and other details is totally optional.
  • Automatic collection: We automatically collect a variety of information associated with your device’s usage of our products and services. For example, when a user visits ZainTech website, the server used will record the following information just as any other website does.
    • Your IP Address
    • The date and time of your visit
    • The type of Internet Browser used
    • The URL of any website that you were directed from
    • The personal information from your computer when you browse this site will be collected voluntarily.
  • Information from other legitimate sources: We also collect information from certain organizations, publicly available sources where appropriate and to the extent that we have legal grounds or regulatory obligations to do so. These may include background verification agencies, roaming partner network providers and national regulatory agencies.
How We Use Your Data

The information that we collect from you will help in better processing of your requests where applicable. It will never be sold to any third party for their own marketing purposes without your express permission in writing unless it is used on an aggregated basis for statistical and research purpose without any information which can be used to identify you.

We use your information to:

  • Process billing and collection of the fees for products, Solutions and services subscribed.
  • Deliver products and/or services to customers.
  • Transact with suppliers and business partners.
  • Comply with Legal & Regulatory requirements.
  • Protect information from unauthorized access or misuse;
  • Communicate with you about our service, products or apps and to promote our services.
Our Security Practices

We adopt best practices and standards in line with international standard ISO/IEC 27001, to include, technical, operational, managerial and physical security controls to protect your personal information from unauthorized access, or disclosure while it is under our control.

Non-Disclosure of Customer's Data:

ZainTech will maintain the privacy and confidentiality of all information collected for the duration it is under ZainTech’s control. Such information may only be disclosed when required by law or when in good faith we believe that such action is necessary or desirable to comply with the law, protect or defend the rights or property of ZainTech, this site or its users. Information may also be disclosed to authorized third parties (service providers, joint venture partners, ect.) for legitimate business requirements, to help us provide you with the products and services and efficiently serve you . ZainTech shall ensure due care and diligence to ensure confidentiality of information entrusted with such parties.

Data Retention

ZainTech shall retain information as per business need and as applicable laws, regulations, or government orders require. When we dispose of information, we use industry best practices for disposal procedures.

Securing Your Data

We have security teams who constantly review and improve technical and organizational measures to protect your information in our systems from unauthorized access, accidental loss, disclosure or destruction.

Your Rights

You are entitled to certain legal rights in relation to the personal information that we hold about you.

  • Right to access personal data

You have the right to make a request for a copy of the personal data that is held with ZainTech. To make this request as an individual or an enterprise customer, please contact our Customer Services team.

  • Right to correct personal data

You have the right to have information held about you corrected if it is not accurate. If what we hold on you needs updating, or you think it may be inaccurate, you can contact us through our website by pressing on “contact us” button or contact our Customer Services team.

  • Right to restriction of processing

You have the right to restrict processing your data, however exercising this right may not enable ZainTech to fulfil your service requests and ensure service performance.

  • Right to data portability

You have the right to be able to take with you the personal data you provided to us in certain circumstances, whenever it is permitted by law. In order to do this, you can contact us through our website by pressing on “contact us” button or contact our Customer Services team.

  • Right to object

You have the right to object to receive marketing messages from ZainTech by choosing to opt out of all marketing communications or only selected methods (e.g. email, SMS, MMS, phone or post).

  • Right to object to profiling

You have the right of your data not being subject to a decision based on automated processing and profiling, however, exercising this right may not enable ZainTech to design and promote products and services tailored to your needs.

  • Right to erasure

ZainTech shall strive to only process and retain your data for as long as we need to. In certain circumstances you have the right to request that we erase personal data of yours that we hold. If you feel that we are retaining your data longer than we need, it is worth first checking that your contract with ZainTech has been terminated, which you can do with Customer Services. For more information on retention periods, refer to section in this Privacy Policy called ‘Data Retention’.

  • To manage cookies and understand more about what they are:

Our website uses cookies to enhance your user experience. If you wish to understand more about what these are? We encourage you to review our 'Cookies’ section of this Privacy policy.

Cookie Policy

Like any other website, ZainTech’s website may use “cookies” and other technologies such as pixel tags to optimize your browsing experience. Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page and helps to analyze how well the website is performing. It will also help in recognizing your device when you re-visit the website. These cookies will not collect any information when you are not accessing the website and can be deleted at any time by you.

A website uses different cookies to improve the user experience:

  • Single session cookies: These enable the site to keep track of your movement from page to page to ensure that you will not be asked for the same information you have previously given during your visit to the site.
  • Remember me cookies: These cookies enable the site to remember your personal preferences such as log in details to improve the user experience for example by avoiding you having to re-enter these details on each visit to the site.
  • Remember my language cookies: These enable the site to retain your language preference for future visits to improve the user experience.
  • Persistent cookies: These cookies enable us to collect information such as number of visitors to the site and pages visited to analyze user behavior.
Definitions

Throughout this policy you may come across various terms and technical jargons that are used to describe our stance on privacy matters.

  • PrivacyThe quality or state of being apart from company or observation.
  • CookieData sent by an internet server to a browser used to identify the user or track their access to the server.
  • PortabilityThe ability to be easily carried or moved.
  • ProfilingThe recording and analysis of a person's behavioral characteristics, to assess or predict their capabilities in a certain sphere or to assist in identifying categories of people.
How to Contact Us

Your opinion matters to us – if you have any questions/complaints about our privacy policy, you can direct your questions at: info@zaintech.com. All information provided to ZainTech will be treated as confidential. Our call centers, support chats and online forms are also available among other channels to contact ZainTech for questions and comments.

Expediting a Requested Transaction

Necessary information required from you will be submitted to us without any obligation. In the event where you fail to provide the requested information to us, we will not able to process the request placed by you. This information will help in better processing of your requests where applicable.

Updating Privacy Policy

With the swift and fast developing services, ZainTech reserves the right to change the Privacy Policy or Terms & Conditions when necessary. The policy shall be updated on an annual basis and when needed, in accordance with regulations.

Region Specific Privacy Regulations

In addition to the above mentioned, please refer to the applicable region-specific privacy information below:

  • For Bahrain: Click Here
  • For Kuwait: Click Here
  • For Saudi Arabia: Click Here
  • For Jordan: Click Here
  • For UAE: Click Here
  • For Iraq: Click Here
Additional Notice to Bahrain Residents

This section supplements the information in our Privacy Policy above and applies solely to Bahrain residents and Personal Data collected, processed, stored and used in connection with users access or use of ZainTech’s services and site in accordance to the Bahrain's Personal Data Protection Law (Law no. 30 0f 2018) (PDPL) as well as Bahrain’s The Cloud Computing Services Law No. 56 of 2018.

As per Personal Data Protection Law (Law no. 30 0f 2018) (PDPL) “Personal Data” includes any information of any form relating to an identified or identifiable individual, either directly or indirectly, particularly through his/her personal ID number or one or more of his/her physical, physiological, intellectual, cultural or economic characteristics or social identity. To determine whether an individual is identifiable, all means used by, or that may be available to, the data manager or any other person should be considered.

Lawful Basis of Processing Your Personal Data

We collect and process your Personal Data only when we have valid consent obtained from you. We will process your data without your consent only for the following cases:

  • Implement a contract to which the data owner is a party.
  • Conclude a contract at the data owner’s request.
  • Implement an obligation prescribed by law contrary to a contractual obligation or an order from a competent court or the public prosecution.
  • Protect the vital interests of the data owner.

We will only process relevant, enough, and not excessive data in view of the purpose of the collection or subsequent processing.

Breach Notification

In case of breach of your personal data, we will notify the relevant authority as required under PDPL, which can further investigate the incident and can notify you of the breach.

Data Security

We respect your privacy and are committed to protecting the personally identifiable information that you provide, in connection with your use of our site. We take enough technical and organizational measures capable of protecting data against unintentional or unauthorized destruction, accidental loss, unauthorized alteration, disclosure or access, or any other form of processing. Wherever your data is processed by data processor, we ensure that:

  • Data processer will provide enough guarantees regarding the technical and organizational measures that must be followed during processing of your data.
  • We will take reasonable steps to verify compliance with these measures.
  • Processing must comply with a written contract between us and the data processor which stipulates that:
    • The data processor shall only process data in accordance with our instructions.
    • The data processor shall comply with the same security and confidentiality requirements prescribed for us.
Data Anonymization and Pseudonymization

We will process the personal data only in a form where data owner cannot be identified. Once the purpose of processing is over, we will archive your data for historical, statistical or scientific research purpose and same will be kept in an anonymized way.

Data Transfer

We may transfer your data outside Bahrain only in the following cases:

  • The transfer is made to a country or region listed in a statement that the PDPL prepares and updates, listing countries and regions that the PDPL deems to have statutes or regulations in effect that provide enough personal data protection. This statement shall be published in the official gazette.
  • The transfer occurs after specific permission issued by the PDPA on a case-by-case basis if it deems that the data will be sufficiently protected. The PDPA’s discretion shall be based on all circumstances surrounding the data transfer process, specifically:
    • The nature of the data to be transferred, the purpose of processing and the processing period.
    • The country or region from which these data originate, their destination and the personal data protection measures available in these countries or regions.
    • The international agreements and relevant statutes in effect in the country or region to which the data will be transferred. This permission may be conditional or for a specific period.
  • For the execution of contract with data processor.
Data Stored on Cloud

We are using PBX cloud services for operations related to personal data. In case of any judgment or order issued from a foreign authority in connection with your data, we will inform you about the same.

Additional Notice to Kuwait Residents

This section supplements the information in our Privacy Policy above and applies solely to Kuwait residents and Personal Data collected, processed, stored and used in connection with users’ access or use of ZainTech’s services and site in accordance with Kuwait’s E-Transaction Law, Data Privacy Protection Regulation (CITRA Resolution No. 42 of 2021) and CITRA Cloud Computing Regulation

As per Data Privacy Protection Regulation (CITRA Resolution No. 42 of 2021) and CITRA Cloud Computing Regulation, Personal Data means

  • Data relevant to a natural/legal person whose identity is identified or can be identified through such data directly using name, identity, financial health, racial or religious information or any information that allows the identification of a person's geographical location or personal tracking systems, personal fingerprint or genetic fingerprint, or through a combination of available data and any other data, or any audio file including the person's voice, and any other identifier that allows physical or online contact with the person who shall be referred to as the data owner.
  • Information or a group of information, if collected together, through which the identity of the individual can be clearly and directly inferred, and it also includes any information that can be linked indirectly as the location data for a specific person regardless of whether the identity of the individual is clear or not from that information or from a set of information and other information, and as mentioned in the regulatory framework for cloud computing issued by the Communications and Information Technology Regulatory Authority”. It also includes any data that can be used to reach the identity of any person. It is divided into seven sections as follows: Personal Identification, Contact Data, Marketing and Communications Data, behavioral data, technical data, aggregate data, special categories of personal data.

As per CITRA Cloud Computing Regulation, Special categories of personal data mean private data related to race, origin, religion, sect, philosophical beliefs, political or membership opinions (unions or associations of public benefit) or data related to health and genetic and vital data.

Lawful Basis of Processing Your Personal Data

We collect and process your Personal Data only when we have valid consent obtained from you. In case if you are person below age of 18, we will process your data only after collecting consent from your parents. We may obtain a consent to process your personal data from the person authorized by you. We will only process the data for the purposes which are listed in this privacy policy. In case if data is used for purposes other than the mentioned in this policy, we will inform you about the same. We are collecting your data using the means which are defined in this policy.

Data Security

We respect your privacy and are committed to protecting the personally identifiable information that you provide, in connection with your use of our site. We take enough technical and organizational measures capable of protecting the personal data and information against loss, damage, disclosure, replacement with incorrect data or information, or addition of untrue information. Such technical measures include but not limited to

  • Encryption
  • Backup of personal data
  • Continuous monitoring and assessing effectiveness of security measures
  • Rules/directives authorized by CITRA regarding business continuity, disaster recovery, risk management
  • Data protection and privacy policies
  • Staff Training
  • Prepare records and make it available to CITRA
  • 24-hour communication with Data Protection Officer
Data Transfer

We may transfer your data outside Kuwait only when we have obtained consent from you, or the person authorized by you to do so. We will also inform you in case we want to transfer your data outside Kuwait. For the data which is stored on our private cloud, we will not transfer to any public or hybrid cloud.

Data Minimization

We are only collecting relevant data which is required to fulfil defined purpose of processing and will always keep your data up to date.

Data Breach Notification

We will immediately notify CITC as well as you in case of any breach of your personal data.

Additional Notice to Saudi Arabia Residents

This section supplements the information in our Privacy Policy above and applies solely to Saudi Arabia residents and Personal Data collected, processed, stored and used in connection with Users access or use of ZainTech’s services and site in accordance with Saudi Arabia’s General Principles for Personal Data Protection and CITC’s Cloud Computing Regulatory Framework 2018 and the Personal Data Protection Law of 2021.

As per Saudi Arabia’s Personal Data Protection Law of 2021, Personal Data means “any element of data, regardless of source or form whatsoever, which independently or when combined with other available information could lead to the identification of a person including but not limited to: first name and last name, Saudi national ID number, addresses, phone, number, bank account number, credit card number, health data, images or videos of that person."

As per CITC’s Cloud Computing Regulatory Framework 2018

  • Subscriber Data here means subscriber content (software, text, files, audio, video, images, graphics, animations, illustrations, information, personal, business or other data) that is related to a natural person who is specifically identified directly or indirectly as a cloud computing user, specifically by referring to an identification number or one or more elements that allow the user to be identified by.
  • Additionally, subscriber content means any content provided or generated by a Cloud Subscriber that is stored or processed in a Cloud system pursuant to a Cloud Contract for the provision of Cloud Services through the Cloud system to that cloud subscriber.

Cloud Computing Service Provider (CSP): Any legal person who provides one or more of the cloud computing services of all types detailed above to subscribers of cloud computing services and may own a center or data centers that they manage partially or completely and use them to provide cloud computing services, directly or indirectly, through

Cloud Computing Subscriber (Subscriber): An individual, government entity, or private company who uses cloud computing services by purchasing those services from a cloud computing service provider under a cloud computing contract.

Lawful Basis of Processing Your Personal Data

We make sure that your data collection and processing shall be done in a lawful and in a transparent manner. We will only collect data that is necessary and required for the purpose specified in this Privacy Policy, and collect and process your personal data only when we obtain your express consent, except in the event that the processing is in your real interest subject and contact with you is impossible or difficult to achieve or in the case where the processing is under the applicable laws and regulations or in implementation of a previous agreement in which you are a party in.

We will process your data stored on the cloud only as per our Agreement.

Retention of Your Personal Data

We will retain your personal data only till it fulfills the purpose mentioned in this privacy policy and in accordance with approved instructions received by the Communications and Information Technology Commission (referred to as ‘CITC’). We will retain such data in a form where data owner cannot be identified.

Transfer of Personal Data

We will not transfer your personal data outside of KSA unless in the case of extreme necessity to preserve your life or your vital interests, or to prevent, examine or treat a disease, or if in implementation of an obligation under which KSA is a party, or to serve the interests of KSA or for any other purposes determined by the applicable law and regulations of the KSA.

The above is still predicated upon complying with the following conditions:

the transfer or disclosure does not prejudice national security or the vital interests of KSA;

there are sufficient guarantees for preserving the confidentiality of your Personal Data to be transferred or disclosed, so that the standards are not less than the standards in the applicable law and regulations;

the transfer or disclosure must be limited to the minimum Personal Data needed; and

the competent authorities approve the transfer or disclosure, as determined by the applicable laws and regulations.

However, the competent authority may exempt, on a case-by-case basis, the personal data from being bound by these conditions if the transfer does not prejudice national security or the vital interests of KSA; if the competent authority, jointly or severally with other parties, determines that the Personal Data will have an acceptable level of protection outside of KSA; and the Personal Data is not Sensitive Data.

Data Breach Notification

We will immediately notify you as well as the competent authorities case of any breach of your personal data.

Data Security

We will develop and implement a privacy program to maintain personal data protection, where we will develop, document, implement, and enforce policies and procedures for maintaining your data privacy. In addition, we will obtain approval from CITC for this data protection plan, and we will also regularly report this program’s activities to CITC to ensure utmost safety for your data. Further, we will make sure confidentiality, integrity and availability of your data stored on cloud is ascertained based on the data classification levels issued by National Data Management Office or Regulatory Supervisory Authority. Further, we will develop cyber-security and data protection safeguards for your data stored on cloud to protect it while storing, processing, transmitting or outsourcing.

Data Subject Rights

In addition to the data subjects’ rights mentioned in the main section of this notice, you have following right:

  • Right to knowledge:

This includes informing you of the legal or practical justification for collecting your personal data, and the purpose of that collection, and not to process your data later in a manner inconsistent with the purpose of its collection or in cases other than those stipulated in the applicable laws and regulations.

  • Right to your access to your personal data

This includes the right to review and obtain a copy of your personal data in a clear format and conforming to the content of the records, free of charge, in accordance with what is determined by the applicable laws and regulations.

  • Right to request that your personal data be corrected, completed, or updated

If what we hold on you needs updating, or you think it may be inaccurate, you can contact us on our website by pressing on the “contact us” to update it or contact our Customer Services team.

  • Right to request that your personal data be destroyed

You can contact us in order to destroy your personal data we hold if it is no longer needed.

The following cases are excluded:

If all means of knowing who the owner of these data is, are removed, in accordance with the limits provided by the applicable laws and regulations.

If there is a legal justification that necessitates keeping it for a specific period, in which case it shall be destroyed after the expiry of this period or the purpose of its collection, whichever latest.

If your personal data is closely connected to a case before a judicial authority and its retention is required for this purpose, in this case it shall be destroyed after the completion of the judicial proceedings for this case.

Additional Notice to Jordan Residents

This section supplements the information in our Privacy Policy above and applies solely to Jordan residents and Personal Data collected, processed, stored and used in connection with Users access or use of ZainTech’s services and site in accordance with Jordan’s Cloud (Platforms & Services) Policy 2020

Transfer of Personal Data

In case we need to transfer your data stored on cloud to other Cloud Service Provider, we will obtain written approval from you and we will also sign NDA with other Cloud Service Provider to ensure security of your data

Data Security

We will develop information and network security controls to protect cloud systems and data to avoid unauthorized access and violations of data. We will implement required technical and security controls and measures such as encryption or anonymization to protect data, whether data is stored or being transferred.

Data Subject Rights

In addition to the data subjects’ rights mentioned in the main section of this notice, you have following right:

  • Right to retrieve data:

You have the right to retrieve your information we stored about you on the cloud platform.

Data Breach Notification

We will immediately notify you as well as Telecommunication Regulatory Commission (TRC) and the Ministry in case of any breach of your personal data or any technical defect that occurs to the provided services in accordance with the contract and SLA.

Additional Notice to United Arab Emirates Residents

This section supplements the information in our Privacy Policy above and applies solely to United Arab Emirates residents and Personal Data collected, processed, stored and used in connection with Users access or use of ZainTech’s services and site in accordance with The UAE Federal Decree-Law No. 45 of 2021 Regarding the Protection of Data Protection, The Federal Law No. 15 of 2020 on Consumer Protection, Federal Law No. 5 of 2012 on Combatting Cybercrimes and its amendment by the Federal Law No. 12 of 2016 and Federal Law No. 1 of 2006 on Electronic Commerce and Transactions.

As per UAE Data Protection Law, “Personal Data” is defined as any data relating to an identified natural person, or one who can be identified directly or indirectly by way of linking data, using identifiers such as name, voice, picture, identification number, online identifier, geographic location, or one or more special features that express the physical, psychological, economic, cultural or social identity of such person. It also includes Sensitive Personal Data and Biometric Data.

“Sensitive Personal Data” is defined as any data that directly or indirectly reveals a natural person's family, racial origin, political or philosophical opinions, religious beliefs, criminal records, biometric data, or any data related to the health of such person, such as his/her physical, psychological, mental, genetic or sexual condition, including information related to health care services provided thereto that reveals his/her health status.

“Biometric Data” is defined as Personal Data resulting from Processing, using a specific technique, relating to the physical, physiological or behavioral characteristics of a Data Subject, which allows or confirms the unique identification of the Data Subject, such as facial images.

Lawful Basis of Processing Your Personal Data

We will collect and process your Personal Data in a fair, transparent and lawful manner where the Personal Data will be collected for a specific and clear purpose and will not be processed at any subsequent time in a manner incompatible with that purpose. However, Personal Data may be processed if the purpose of Processing is similar or close to the purpose for which such data is collected.

Appropriate measures and procedures will be in place to ensure erasure or correction of incorrect Personal Data. Personal Data will be kept securely and protected from any breach, infringement, or illegal or unauthorized Processing by establishing and applying appropriate technical and organizational measures and procedures in accordance with the laws and legislation in force in this regard.

Personal Data may not be kept after fulfilling the purpose of Processing thereof. It may only be kept in the event that the identity of the Data Subject is anonymized using the “Anonymization” feature.

Breach Notification

In case of breach of your personal data, we will notify you as well as the relevant authority as required under UAE Data Protection Law.

Data Security

We shall put in place sufficient technical and organizational measures to protect and secure Personal Data, preserve its confidentiality and privacy, and ensuring that such personal data is not breached, destroyed or altered.

Transfer of Personal Data

We may transfer your personal data can to countries approved by the Data Office as having an “adequate level of protection”. These cover countries that either have data protection legislation in place or where the specific country has acceded to bilateral or multilateral agreements relating to the protection of personal data.

Additional Notice to Iraq Residents

This section supplements the information in our Privacy Policy above and applies solely to Iraq residents and Personal Data collected, processed, stored and used in connection with Users access or use of ZainTech’s services and site in accordance with the relevant laws in Iraq.

Transfer of Personal Data

In case we need to transfer your data stored on cloud to other Cloud Service Provider, we will obtain written approval from you and we will also sign NDA with other Cloud Service Provider to ensure security of your data

Data Security

We will develop information and network security controls to protect cloud systems and data to avoid unauthorized access and violations of data. We will implement required technical and security controls and measures such as encryption or anonymization to protect data, whether data is stored or being transferred.

Data Subject Rights

In addition to the data subjects’ rights mentioned in the main section of this notice, you have following right:

  • Right to retrieve data:

You have the right to retrieve your information we stored about you on the cloud platform.

Data Breach Notification

We will immediately notify you as well as the relevant authorities in Iraq case of any breach of your personal data.

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