Privacy Policy
ElphaTap values the privacy of individuals who use our websites and related services.
In this Policy, “ElphaTap”, “we” or “us” refers to ElphaTap, as a product of ELPHA MARKETING SERVICES company established in Dubai 2021, UAE. We take privacy seriously and have adopted technical and organizational measures designed to protect your data. This privacy policy (the “Policy”) explains how we collect, use, and share information from users of our Services. If you are located in the United Arab Emirates Area (“UAE”), this Policy informs you of your choices and our practices concerning your Personal Information (as defined below).
For the purpose of this Policy, “Personal Information” means any information relating to an identified or identifiable individual. This includes Personal Information collected and processed by us when you access our websites (including ElphaTap.com) (the “Website”), the ElphaTap app, and the services related to them (collectively, together with the Website, ElphaTap app, and the related services, our “Services”). This Policy describes the Personal Information we gather from you on our Services, how we use and disclose such Personal Information, your rights and choices with respect to your information, and how you can contact us if you have any questions or concerns. Beyond this Policy, your use of our Services is also subject to our Terms of Use.
Personal Information We Collect
We may collect and use the following Personal Information about you:
Personal Information You Provide to Us.
Communications with us. When you contact us directly, we may receive additional information about you. For example, when you contact us for customer support, we may receive your name, email address, the content of a message or attachments you may send to us, and other information you choose to provide. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.
Transaction-related information. When you purchase something on the Website or the ElphaTap app, you may be asked to provide us with your information, such as your name, phone number, and address. Your payment-related information, such as credit card or other financial information, is collected by our third-party payment processors on our behalf.
Service-related information. When you use our Services, you can choose to provide certain Personal Information, including your contact information, social media links, and location.
Ambassador information. When you apply to become an ElphaTap Ambassador in our affiliate program, you may provide us with additional information about you such as your name, email address, pictures of you, social media links, phone number, postal address and other information you choose to provide.
Product reviews. When you reply to our request to review and rate your experience with our Services, you may provide us with additional information about you. The information we collect from you varies depending on the review but typically includes your name, the Service you used, and your opinion about the Service.
Personal Information We Collect When You Use Our Services.
Location information. When you use our Services, we may infer your general location information, for example, when you use the ElphaTap app.
Device information. We receive information about the device and software you use to access our Services, including IP address, web browser type, and operating system version.
Usage information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, purchases you make, and the dates and times of your visits.
Information from Cookies and Similar Technologies. We and third-party partners collect Personal Information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. We may use both session cookies (which are deleted from your device after you leave the Website) and persistent cookies (which remain on your device for longer or until you delete them manually). A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.
Please review your web browser's "Help" file to learn how to properly modify your cookie settings. Please note that if you delete or choose not to accept cookies from our Services, you may not be able to utilize the features of our Services to their fullest potential.
Personal Information We Receive from Third Parties.
Information from third-party services. We obtain Personal Information from third parties, such as Facebook, Snapchat, YouTube, when you click on third-party buttons or beacons (such as Facebook “like” or “share” buttons, or embedded YouTube video) on our Website. If you choose to link our Services to a third-party account, such as Facebook, Instagram, or Snapchat, we may receive information about you, including your profile information and your photo. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options. If we combine or associate information from other sources with Personal Information that we collect through our Services, we will treat the combined information as Personal Information in accordance with this Policy.
How We Use the Personal Information We Collect
We use the information we collect for the following purposes:
- Communicating with you. We may use your email address or other Personal Information we collect on our Services as necessary to contact you for administrative purposes such as to provide services and information that you request, respond to comments and questions, and otherwise provide customer support.
- Providing the Services and personalizing your experience. We may use your Personal Information to provide and maintain our Services, including to facilitate transactions and payments or to enable you to connect to third-party services or applications. When doing so, we may use your Personal Information to personalize your experience on our Services such as by providing tailored content and recommendations.
- Understanding usage and improving the Services. We use your Personal Information that we collect through our Services to analyze trends and statistics, and to improve and enhance our Services.
- From time to time, we may ask you to participate in surveys we conduct which are in our legitimate interest because they help us understand our userbase and improve our Services. If you participate, we process your registration information and any other information collected through the survey questions.
- We may use your email address and other Personal Information to send marketing communications related to our Services. Generally, you have the ability to opt-out of receiving any promotional communications as described below under Your Rights and Choices. Where required under applicable law, we will only send you promotional emails with your opt-in consent.
- We may use your usage information and other Personal Information to develop and provide you with promotional and advertising materials that may be relevant, valuable or otherwise of interest to you.
- Legal obligation and Compliance. We use your Personal Information to find and prevent fraud, respond to trust and safety issues that may arise, and for compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
- Other Purposes. We may use your Personal Information for other purposes for which we provide specific notice at the time the information is collected.
What Are Cookies and How Do We Use Them.
Cookies are small files of letters and numbers that we store on your browser or your computer's hard drive.
Pixel tags and web beacons are tiny graphic images placed on web pages or in emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our Website and Services.
We use cookies, web beacons, pixel tags, and similar technologies (collectively “Cookies”) to collect information about your browsing activities and to distinguish you from other users of our Services. This aids your experience when you use our Services and also allows us to improve the functionality of our Services. When you use our Services, we collect certain information by automated means, using technologies such as Cookies and browser analysis tools. In many cases, the information we collect using Cookies and other tools is used in a non-identifiable way, without any reference to personal data. We may use Cookies to make our Website usage more efficient to tailor your browsing preferences and improve the functionality of our Website.
Cookies can be used for performance management, and collecting information on how our Website is being used for analytics purposes. They can also be used for functionality management, enabling us to make the user’s visit more efficient by, for example, remembering language preferences, passwords and login details.
Below is an overview of the types of Cookies that we and third parties may use to collect Personal Information.
- Strictly necessary cookies. Some Cookies are strictly required to make our Services available to you. We cannot provide you with our Services without this type of cookie. For example, these cookies allow us to provide login functionality.
- Functional cookies. These Cookies are used to recognize you when you return to our Services. This enables us to adapt our content for you, and remember your preferences (for example, your choice of language or region).
- Analytical or Performance cookies. We also use Cookies for website and app analytics purposes in order to operate, maintain and improve our Services. We may use our own analytics Cookies or use third-party analytics providers such as Google tag manager, to collect and process certain analytics data on our behalf. These providers may also collect information about your use of other websites, apps, and online resources. You can opt out of Google tag manager without affecting how you visit our Services by going to google.com/dlpage/gaoptout or via Google’s Ads settings.
Where required by applicable law, we obtain your consent to use Cookies. You can find more information about your rights and choices, and how to block the use of certain Cookies in the section Your Rights and Choices below.
Our Use of UAE Personal Information.
If you are located in the UAE Area, we only process your Personal Information when we have a valid “legal basis”, including when:
- You have consented to the use of your Personal Information, for example to send you marketing communications or to use cookies and similar technologies.
- Contractual necessity. We need your Personal Information to provide you with our Services, for example, to respond to your inquiries.
- Compliance with a legal obligation. We have a legal obligation to use your Personal Information, for example to comply with tax and accounting obligations.
- Legitimate interests. We or a third-party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third-party ’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
How We Share the Personal Information We Collect
Except as described in this Policy, we will not disclose your information that we collect on our Services to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
- We may share any information we receive with our corporate affiliates for any of the purposes described in this Policy.
- Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.
- Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting google.com/policies/privacy/partners/ .
- Advertising Partners. We may work with third-party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (networkadvertising.org ) or the Digital Advertising Alliance (optout.aboutads.info) . If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the App Choices mobile app to learn more about how you may opt out of personalized ads in mobile apps.
- As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal processes, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others' rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through our Services.
- Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
- Product Reviews. Any information related to your experience with our Service that you provide via our review mechanism may be displayed for promotional purposes.
- We may also disclose your information with your permission.
Your Rights and Choices
Sharing Preferences. For Ambassadors, certain information, such as your username may always be publicly available to others, and other information may be made publicly available to others by default. You can revise, modify, or delete your account information.
Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you may continue to receive administrative messages from us.
How to block Cookies. You can block Cookies by setting your internet browser to block some or all the Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies), you may not be able to access all or parts of our Services. By using our Website, you consent to our use of Cookies and our processing of information collected through such cookies in accordance with this Cookie Policy and our Privacy Notice. You can withdraw your consent at any time by deleting placed cookies and disabling Cookies in your browser or as explained below. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse our Website using your browser's anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our Website may not function properly if you do not accept Cookies or these technologies. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device. We do not process web browsers Do Not Track signals. To learn more about browser tracking signals and Do Not Track, please visit http://www.allaboutdnt.org.
Your UAE Privacy Rights. If you are located in the UAE, you have the additional rights described below.
- You may request access to and receive information about the Personal information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
- You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward, and this will not affect the lawfulness of the processing before you withdraw your consent.
You may exercise these rights by contacting us using the contact details at the end of this Policy. Before meeting your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
2. International visitors
Our Services are hosted in the UAE and are intended for visitors located within the UAE. If you choose to use our Services from regions of the world with laws governing data collection and use that may differ from UAE law, then please note that you are transferring your Personal Information outside of those regions to the United Arab Emirates for storage and processing, which does not have the same data protection laws as your jurisdiction. When we transfer your Personal Information to the UAE, we take steps to comply with applicable data protection law, in particular legal requirements regarding adequate protection for data transfers. Also, we may transfer your data from the UAE to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services.
3. UAE Visitors
If you are located in the UAE, we will comply with applicable UAE data protection law when transferring your Personal Information outside of the UAE. We may transfer your Personal Information to countries which have been found to provide adequate protection by the UAE Commission, use contractual protections for the transfer of Personal Information, transfer to recipients who have adopted Binding Corporate Rules or rely on an appropriate legal derogation. For more information about how we transfer outside of the UAE, or to obtain a copy of the contractual safeguards we use for such transfers, you may contact us using the contact details given below.
Third Parties
Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.
Retention
We take measures designed to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a more extended period. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.
Security
We make reasonable efforts designed to protect your information by using physical and electronic safeguards to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.
Children’s Privacy
We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with Personal Information in violation of this Policy, then you may alert us at legal@elphatap.com.
Update Your Personal Information or Pose a Question
As an Ambassador, you can update your account and profile information or close your account through your profile settings. If you have questions about your privacy on our Services or this privacy policy, please contact us at legal@elphatap.com.
Changes to this Policy
We will post any adjustments to this Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share Personal Information previously collected from you through our Services, we will notify you through our Services, by email, or other communication.
Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us at legal@elphatap.com or get in touch with us using the contact details below:
ELPHA TAP ELECTRONIC CARDS CO. L.L.C.
606 Arenco Tower, Media City, Sheikh Zayed Road, Dubai, United Arab Emirates. If you are located in the UAE, please contact our AE representative via legal@elphatap.com.
Information we collect, Information you provide to us
We collect the personal information you provide to us when you subscribe to marketing emails or SMS. The categories of information we may collect include:
- Personal Identifiers, including email address, name, and telephone number
- Commercial and Financial Information, including purchases
We collect the personal information you provide to us when you purchase one of our products. The categories of information we may collect include:
- Commercial and Financial Information, including credit card or debit card number, purchases, and bank or other financial account number
- Personal Identifiers, including name, email address, telephone number, and postal address
We collect the personal information you provide to us when you created an account via our app or Teams platform. The categories of information we may collect include:
- Personal Identifiers, including name, email address, telephone number, and postal address
- Commercial and Financial Information, including bank or other financial account number, credit card or debit card number, and purchases
We collect the personal information you provide to us when you visited our website. The categories of information we may collect include:
- Personal Identifiers, including email address and name
We collect the personal information you provide to us when you use and communicate with us about our services. The categories of information we may collect include:
- Personal Identifiers, including name, email address, telephone number, and postal address
- Commercial and Financial Information, including credit card or debit card number and purchase
- Professional, including employment-related information
To the extent we process de-identified personal information, we will make no attempt to reidentify such data.
Information collected automatically
We automatically collect internet or other electronic information about you when you visit our website, such as IP address, browsing history and interactions with our website. We also collect geolocation data. This data may be collected using browser cookies and other unique personal identifiers.
Browser Cookies.
We use cookies to create a better experience for you on our site. For example, cookies prevent you from having to login repeatedly, and they help us remember items you've added to your cart. We also use third-party cookies, which are cookies placed by third parties for advertising and analytics purposes. You can control these cookies through your browser settings.
Do Not Track.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. When we detect a Do Not Track signal, we place a U.S. Privacy String setting in your browser so that any third-party who respects that signal will not track your activity on our website. We also respect the Global Privacy Control (GPC) signal, a user-enabled global privacy control that opts you out of the sale of personal information. GPC is supported by certain internet browsers or as a browser extension.
Information from other sources
We may collect personal information about you from third-party sources, including Ad Networks, Data Analytics Providers, Operating Systems, Other consumers (e.g., referrals), and Social Networks.
How long we keep your data
We do not retain data for any longer than is necessary for the purposes described in this Policy. When you purchase a product from us, we will keep the information related to your purchase so we can fulfill the order and after that we will keep it for a period that allows us to handle or respond to any complaints or concerns relating to your purchase. If you stop interacting with us as a customer, we will remove or anonymize information kept for that purpose after 7 years.
How we share and disclose information
Information Disclosed for Business or Commercial Purposes in the Last 12 Months, and Categories of Parties Disclosed To
We may disclose the following personal information about you when you subscribe to marketing emails or SMS:
Personal Information Disclosed |
Recipient (by Category) |
| Personal Identifiers | Service Providers, Shipping Services, Data Analytics Providers, Payment Processors, and Ad Networks |
| Online Identifiers | Service Providers, Data Analytics Providers, and Ad Networks |
| Internet Activity | Service Providers, Data Analytics Providers, and Ad Networks |
| Geolocation Information | Service Providers and Data Analytics Providers |
| Commercial and Financial Information | Shipping Services, Data Analytics Providers, Service Providers, Ad Networks, and Payment Processors |
We may disclose the following personal information about you when you purchased one of our products:
Personal Information Disclosed |
Recipient (by Category) |
| Personal Identifiers | Service Providers, Shipping Services, Data Analytics Providers, and Payment Processors |
| Online Identifiers | Service Providers, Data Analytics Providers, and Ad Networks |
| Geolocation Information | Service Providers |
| Internet Activity | Data Analytics Providers, Service Providers, and Ad Networks |
| Commercial and Financial Information | Shipping Services, Data Analytics Providers, Service Providers, Ad Networks, and Payment Processors |
We may disclose the following personal information about you when you created an account via our app or Teams platform:
Personal Information Disclosed |
Recipient (by Category) |
| Personal Identifiers | Service Providers, Sales & Marketing Tools, and Data Analytics Providers |
| Online Identifiers | Service Providers, Sales & Marketing Tools, and Data Analytics Providers |
| Geolocation Information | Service Providers and Data Analytics Providers |
| Internet Activity | Service Providers and Data Analytics Providers |
| Commercial and Financial Information | Service Providers |
We may disclose the following personal information about you when you visited our website:
Personal Information Disclosed |
Recipient (by Category) |
| Online Identifiers | Data Analytics Providers, Service Providers, and Ad Networks |
Internet Activity |
Data Analytics Providers, Service Providers, and Ad Networks |
| Personal Identifiers | Service Providers and Ad Networks |
| Geolocation Information | Service Providers |
We may disclose the following personal information about you when you use and communicate with us about our services:
Personal Information Disclosed |
Recipient (by Category) |
| Online Identifiers | Service Providers, Sales & Marketing Tools, Data Analytics Providers, Shipping Services, and Ad Networks |
| Internet Activity | Service Providers, Data Analytics Providers, and Ad Networks |
| Personal Identifiers | Service Providers, Sales & Marketing Tools, Data Analytics Providers, and Shipping Services |
| Geolocation Information | Sales & Marketing Tools, Service Providers, and Data Analytics Providers |
| Commercial and Financial Information | Shipping Services, Data Analytics Providers, Service Providers, and Ad Networks |
| Professional | Service Providers |
Collection and Disclosure of Personal Information
The personal information we collect is described above in Information we collect. The personal information we disclose for business or commercial purposes is described above in How we share and disclose information. The length of time for which we retain personal information is described above in How long we keep your data.
Business and Commercial Purposes for Collection
We collect personal information for the following business purposes:
- Advertising and Marketing
- Error Management
- Internal Research
- Provide Products or Services
- Quality Assurance
- Security
- Short-Term Transient Use
Information “Sharing” and “Selling”
We "share" certain personal information with third-party ad networks for purposes of behavioral advertising, including Commercial and Financial Information, Internet Activity, Online Identifiers, and Personal Identifiers. This allows us to show you ads that are more relevant to you.
We use third-party data analytics providers, and this may be considered a "sale" of information.
Right to Know
You have the right to request to know the following about the personal information we have collected about you in the past 12 months:
- the categories and specific pieces of personal information we have collected about you
- the categories of sources from which we collect personal information about you
- the business and commercial purposes for which we collect personal information
- the categories of third parties with whom we share the information
- the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose
The information we would provide to you in response to a Request to Know Categories is contained in this Privacy Notice. To access the specific personal information we have about you, submit a Request to Know via the link above. If you make a Request to Know more than twice in a 12-month period, we may require you to pay a small fee for this service.
Right to Delete
You have the right to request that we delete any personal information about you that you have provided to us. We will permanently delete from our records any personal information that is not necessary for our business operations and direct our service providers to do the same.
We consider information to be necessary for our business operations if it is used to:
- Complete an obligation to you that you have requested
- Detect and resolve issues related to security or functionality
- Comply with legal obligations
- Enable solely internal uses
Right to Non-Discrimination
If you exercise your consumer rights:
- We will not deny goods or services to you
- We will not charge you different prices or rates for goods or services, including through the use of discounts or other benefits or penalties
- We will not provide a different level or quality of goods or services to you
Right to Opt-Out
You have the right to opt out of any selling and sharing of your personal information. You may exercise your right to opt out.
Request Verification
Before we can respond to a Request to Know or Request to Delete, we will need to verify that you are the consumer who is the subject of the request. Verification is vital for preventing fraudulent requests and identity theft. Requests to Opt-Out do not require verification.
Typically, identity verification will require you to confirm certain information about yourself based on information we have already collected. For example, we will ask you to verify that you have access to the email address we have on file for you. If we cannot verify your identity based on our records, we cannot fulfill your request.
For a request that seeks specific personal information, we ask that you sign a declaration stating that you are the consumer whose personal information is the subject of the request, as required.
In some cases, we may have no reasonable method by which we can verify a consumer's identity. For example:
- If a consumer submits a request, but we have not collected any personal information about that consumer, we cannot verify the request.
- If the only data we have collected about a consumer is gathered through website cookies (i.e. the consumer visited our website but had no other interaction with us), we are unable to reasonably associate a requester with any data collected; therefore, we cannot verify the request.
- If we process a consumer’s information as a service provider to another organization, we are not permitted to respond in a substantive way to that consumer’s UAE Policy Act request. We will, however, assist the organization in fulfilling your privacy request.
Authorized Agent
A UAE resident's authorized agent may submit a Request to Know or a Request to Delete under the UAE Policy Act by emailing us at privacy@elphatap.com. Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described above. We will also ask for proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf. An authorized agent that has power of attorney pursuant to UAE Probate Code must submit proof of statutory power of attorney, but consumer verification is not required.
If you have trouble accessing this notice, please contact us at privacy@elphatap.com.
Contact Us
If you have any privacy-related questions, please send them to privacy@elphatap.com.
Notice Marketing Emails
A consumer may unsubscribe from our marketing emails by using the unsubscribe link in the email footer at any time. A consumer may unsubscribe from our marketing SMS texts by sending "STOP".
UAE Privacy Notice (GDPR)
This section provides additional information for people in the United Arab Emirates (UAE). The terms used in this section have the same meaning as in the General Data Protection Regulation and the UAE Data Protection Act (GDPR). The term “personal information” as used in this notice has the same meaning as “personal data” in the GDPR.
Collection and Disclosure of Personal Data
The personal data we collect is described above in Information we collect. The personal data we disclose for business or commercial purposes is described above in How we share and disclose information. The length of time for which we retain personal data is described above in How long we keep your data.
We may disclose your personal information to the following third-party controllers for business purposes: Instagram Ads, Facebook Ads, Google Ads, PayPal – Pay with PayPal, Venmo, Pay Later, Clearbit Enrich, Greenline Logistics. To understand how these parties handle your data, please refer to their respective privacy policies.
Lawful Bases and Legitimate Interests
We process personal data on the following lawful bases:
- Complying with legal obligations
- Fulfilling contracts
- Consent
- Legitimate interests
- Public interest
- Vital interest of the individual
Where we process personal data on the basis of our legitimate interests, we pursue the following interests: Creating Customer Profiles, Delivering Targeted Ads, Fulfilling Customer Orders, Improving our Products & Services, Organizing & Managing Data, Providing Customer Support, and Sending Promotional Communications.
International Data Transfers
We may send the personal data of individuals in the UAE to third countries, where it may be stored or processed, for example, on our service providers' cloud servers. When we transfer personal data, we rely either on Adequacy Decisions as adopted by the UAE Federal Data Protection Law based on Regulation (UAE) (GDPR), Standard Contractual Clauses (SCCs) issued by the E.C. or International Data Transfer Agreements (IDTAs) approved by the U.K. Information Commissioner's Office. Data protection authorities have determined that the SCCs and IDTAs provide sufficient safeguards to protect personal data transferred outside the UAE.
Privacy Rights
Individuals in the UAE have the following rights regarding their personal data. You can exercise your rights using the request form at the top of this page. Once you submit a request, we will verify your identity and process your request in most cases, within 30 days.
Right to access. You have the right to request a copy of the personal data we hold about you.
Right of portability. You have the right to ask us to transfer your data to another party.
Right to rectification. You have the right to request that we rectify any incorrect information we have about you.
Right of erasure. You have the right to request that we erase (delete) any personal information we hold about you.
Right to lodge a complaint with a supervisory authority. You have a right to lodge a complaint with a supervisory authority. For more information.
ElphaTap privacy@elphatap.com