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Privacy Policy

1. Introduction

Woo Holdings together with any or all of our affiliates is committed to maintaining the confidentiality, integrity and security of personal data collected from our customers, in accordance with all applicable laws. The words “our”, “we” , “us” or "company"  where they appear herein refer to Woo Holdings, unless the context indicates otherwise.

This Privacy Policy defines our procedures in respect of maintaining the confidentiality, integrity and security of all personal data collected and stored by us through all channels and means including our corporate office, websites, and online store.

This Privacy Policy also covers any additional personal information that we may collect from customers and process, during or through other interactions, either directly with Woo Holdings or through our data processors.

We take the protection of your personal and sensitive data seriously, and treats your data in accordance to applicable data protection regulations.

This policy should be read in conjunction with any other privacy notices or fair processing notices and product terms and conditions we may provide on specific occasions when we are collecting or processing Personal Data.

This privacy policy has been developed in line with the provisions of the Bahrain Personal Data Protection Law (No. 30 of 2018) (“PDPL”) which came to effect on 1 August 2019.

Whenever an update occurs, we will post it on our website and we will inform our customers of any significant updates.

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2. Definitions

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2.1 Data or Personal Data

Any information in any form relating to an identifiable individual, or an individual who can be identified, 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.

In order to determine whether an individual could be identified, all the means used by, or that may be available to, the Data Manager or any other person shall be taken in consideration.

Personal data that we collect may include names, telephone numbers, emails and addresses. The type of personal data and supporting documentation that we may obtain from you is as set out in our contact form or website cookies.

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2.2 Sensitive Personal Data

Any personal information that reveals, directly or indirectly, the individual’s race, ethnicity, political or philosophical views, religious beliefs, union affiliation, criminal record or any data related to his/her health or sexual life.

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2.3 Data Manager

The person who decides, solely or in association with others, the purposes and means of processing certain personal data. Where such purposes and means are prescribed by Law, the Data Manager shall be the person responsible for processing all relevant personal data.

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2.4 Data Processor

The person who processes personal data for and on behalf of the Data Manager, not including persons who works for the Data Manager or Data Processor.

 

2.5 Data Processing

Any operation or set of operations carried out on personal data by automated or non-automated means, such as collecting, recording, organising, classifying in groups, storing, modifying, amending, retrieving, using or revealing such data by broadcasting, publishing, transmitting, making them available to others, integrating, blocking, deleting or destroying them.

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2.6 Direct Marketing

Any communication, by any means, through which a marketing or advertising material is directed to a specific person.

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3. Data We Collect

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3.1 Information Requested and Collected by Us

As part of our legitimate business use, and for the purpose of providing our services, we must and do collect and process the following categories of personal data about our past, existing and prospective customers:

Data Class: Indicative Data Elements (Not an exhaustive list)

Identifiers: Name (First and Last)

Contact Information: Email, Phone number (mobile and fixed), Address

Documents: Any service terms and conditions and/or application forms you conclude between yourself and Woo Holdings

Usage Information: Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Cookies, Log files and Web beacons: Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies. Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity). Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

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Personal data collected and processed by us is restricted to the minimum information that we require in order to provide services to our customers, or to comply with any regulatory provisions or directions as may apply. Not having this information could result in our inability to provide the services requested by our customers or could affect the quality of those services.

In addition to processing personal data we may also aggregate, stratify and analyze anonymized personal data. As personal data that is aggregated and analyzed in this manner is rendered anonymous (i.e. it cannot identity or be linked to individuals) such data is not considered personal data for the purposes of this Privacy Policy.

Aggregated data may include pages visited, time spent you have browsed on your mobile, device or PC. This data is used by us to analyze and improve the quality of our services to you.

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3.2 Information That You Provide Voluntarily

We collect personal data that you provide voluntarily through our website: for example, when completing online forms to contact us, or completing online forms to apply for a job position. Personal data we collect may include:

  • Name

  • Job title, level, job function or role

  • Company or organisation

  • Company data

  • Contact information, including email address and telephone numbers

  • Demographic information, such as industry, country, preferences and interests

  • Other information relevant to client surveys or similar research

  • Information pertinent to fulfilling our services to you

  • Any other personal data that you voluntarily provide to us.

We do not intentionally collect sensitive personal data.

Information provided by you on behalf of a wholly or partially incompetent data owner shall be considered within the limits of the law if you are the legal guardian, executor or custodian.

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3.3 Information That We Collect Automatically

When you visit our websites, we collect certain personal data automatically from your device such as:

  • Your IP addresses

  • Device type

  • Unique device identification number (such as MAC address)

  • Browser type, broad geographic location (on a country or city level)

  • Other technical information.

We also collect information about how your device has interacted with our site, including webpages accessed and links clicked. Collecting this information enables us to better understand visitors who come to our website, such as where they come from and what content on our website is of interest to them. We use this information for internal analytics and to improve the quality and relevance of our website for our visitors.

Please note that Woo Holdings is not responsible for any personal data that may be collected and processed by any third party (i.e. any party other than Woo Holdings) as a result of any person accessing any third party plugin or website though Woo Holdings’s website.

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4. Use of Personal Data

We may process your personal data for any or all of the following purposes:

  • To provide services to you (including services and products offered by subsidiaries, or by online store)

  • To administer our relationship and maintain contractual relations

  • For marketing and business development

  • To comply with our legal and regulatory obligations

  • To establish, exercise or defend legal rights

  • For historical and statistical purposes

  • For research, analytics and enhancement of our services

 

5. Data Disclosure

We will only disclose your personal data to third-parties outside of Woo Holdings in the following circumstances:

  • When explicitly requested by you

  • To perform our obligations under a contractual arrangement with you, or

  • As compelled by a court order or by any other legal or regulatory requirement.

Third-party recipients of personal data may include:

  • Professional advisors such as law firms, tax advisors or auditors

  • Insurers

  • Audit regulators

  • Tax and customs and excise authorities

  • Regulatory and other professional bodies

  • Providers of identity verification services

  • Credit reference agencies

  • The courts, police and law enforcement agencies

  • Government departments and agencies

  • Service providers

  • Emergency services

This website may include links to third-party websites, plug-ins and applications which are not maintained or controlled by Woo Holdings. 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 websites and are not responsible for their privacy statements. When you look at other websites, we encourage you to read the Privacy Policy of every website you visit.

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6. Data Retention

Our policy is to retain personal data only for as long as it is needed. Retention periods are set in accordance with local regulatory and professional retention requirements to meet our professional and legal requirements, to establish, exercise or defend our legal rights, and for archival purposes.

For historical statistical analysis, we may need to retain information for significant periods of time after suitably anonymising the information.

 

7. Transfer of Data Outside Bahrain

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where third party or parties involved in the processing are located. It means that this information may be transferred to and maintained on computers located outside of Bahrain where the data protection laws may differ than those from Bahrain.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

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8. Security

We are committed to safeguarding and for ensuring the application of technical and organizational measures capable of protecting personal data against unintentional or unauthorized destruction, accidental loss, unauthorized alteration, disclosure or access, or any other form of processing.

Our various security measures include encryption, firewalls and access controls. Data is shared within Woo Holdings (including employees, contractors, agents, etc.) on a need to know basis and under strict confidentiality arrangements.

Notwithstanding this, despite our best efforts, we cannot absolutely guarantee the security of data against all threats. We have implemented suitable measures to identify, monitor and report any breaches to personal data in line with the requirements of the law.

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9. User Rights

Under the provisions of the law, you are provided with the following rights in relation to the processing of your personal data:

  • Access

  • Rectification

  • Erasure

  • Restriction of processing

To exercise your rights under the law by contacting us, and you may be required to authenticate yourself with adequate proof of identity.

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10. Changes to this Policy

We reserve the right to update this privacy policy. We will notify users of any changes through appropriate means.

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11. Contact Us

We take your privacy seriously. For questions or concerns about this policy, please contact us at hello@wooholdings.com

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