PRIVACY POLICY
Thank you for using Toby's Estate (“Application”), your loyalty program for
Toby's Estate Club where you can get reward points for your purchases. We
have created this document (“Privacy Policy”) in order to clarify to our User's
(collectively hereinafter referred to as “You” and “Your”) privacy of Your
personal information (“Personal Information”). The provisions set out in this
Privacy Policy prescribe our policies regarding the collection, use, processing
and dissemination of personal information submitted by You to us.
This Application is owned by and operated by Pinnacle Group Company
(“Toby's Estate”) having its registered office at Sharq, Block 7, Omar Ben Al
Khattab Street, Al-Rayah Tower, Floor 18, State of Kuwait
ACCEPTANCE OF POLICY
- This Privacy Policy is supplementary to the Terms and Conditions of Service
("Terms and Conditions"), and is incorporated into the Terms and Conditions by
this reference.
- By providing Us with Your personal information in any way, You agree to be
bound by this Privacy Policy.
- If You are accessing or using our Application, please be aware that the
Application may contain links to websites of third parties. By clicking on such
links, You may be transferred to the website of the third party. We are not
responsible in any way for the privacy practices of such third parties and You are
advised to view and read the privacy statements issued by third parties to ensure
that You understand and agree to the same.
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COLLECTION OF DATA.
- We will always follow the principles of this Privacy Policy and ask You how
You would like Us to communicate with You in order to use of certain services
provided through the Application.
- Registered User: In order to become a Registered User, You need to
register an account with us, You may be required to provide certain information,
including any information which may be used to personally identify You
("Personal Information") and such Personal Information can be used by Toby's
Estate for newsletter for their monthly activity or any sort of application
marketing, in the applicable contact form as part of Your Registration Data.
Personal Information includes Your name, address, phone number(s), date of
birth, gender, profile picture and email address and any other information which
may, or may lead to, the disclosure of Your identity as an individual.
- In this case we will be provided information about You through social media
sites as specified when You log in. We will only use Your information in
accordance with this privacy policy.
- Other Communications: You may also be required to provide Personal
Information when You communicates with Us in any other way, including when
You:
- request for further information on our services. We can also access to Your
personal information through the use of Your mobile in order to access our
Application.
- request for any advice or assistance in relation to the services ; or
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report a problem or contact Us by way of email, telephone call, fax
message, letter or through any other means of communication.
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There is also the possibility of having access to Your personal information
through Google cloud or Facebook.
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USE OF DATA.
- Any Personal Information submitted to Us, together with any other information, material or content You have provided ("Data") shall be used primarily for the purposes to which they were submitted or required.
- We may also decide to use the Data for the following additional purposes:
- to understand what Your needs and requirements are
- to provide personalized content and match the most relevant services for You
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to improve on our marketing and customer service efforts
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in other advertising, statistical compilation or marketing-related purposes; and
- to profile Your information normalferences, for example, understanding how You use the Application, reviewing the nature of Your communication and/or reviewing Your search contents, any service pages You access.
- monitor or improve the performance of, and products and services available through this Application
- monitor compliance with our Terms and Conditions of use of this Application, enforce our rights and protect the safety of others including investigating and if necessary removing any content about which we receive a complaint.
- for any purpose if we are required to do so by any law or other regulatory or government authority.
In case You upload Your personal information to the part of the Application which is accessible to the public, then we may use that information in accordance with our Terms and Conditions of use and there is a possibility that this information can be accessed by the public. Thus we disclaim any responsibility for this.
- Unless You inform us otherwise in accordance with Clause 5.3, we may also use Your Data to communicate with us ("Communications"):
- by sending You notices regarding updates, changes or additions to our services or regarding any promotions which may be of interest to You;
- by inviting You to participate in our surveys;
- by requesting for Your views on our customer support
- by responding to Your requests.
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DISSEMINATION OF DATA.
- Be assured that we will never sell Your Data to any third parties for
commercial gain.
- However, we may disclose Your Data:
- to our consultants, advisors, service providers and agents ("Authorized
Representatives"). They will have access to Your personal information if
necessary to perform their function but they cannot use it or disclose it for any
other purpose, unless You have specifically given them consent to do so ;
- we may share aggregate, non-personally identifiable information, such as
demographics and application usage statistics, with advertisers, sponsors and
other organizations;
- Sharing of information with third parties in case of provision of product and
services available through this Application in partnership with third parties. In this
case the third party would be under obligation to use the personal information
according to this privacy policy. You can also have an access to the identity of
the third party to whom the personal information has been transferred.
- to assist us to achieve the purposes described in
Clauses 3.1 and 3.2; and
- to assist us in our Communications to You (unless
You have informed us that You do not wish to receive any of our
Communications in accordance with Clause 5.3); and
- to our business partners who may communicate with You ("Business
Partner Communications"):
- by sending You notices regarding any promotions
or products or services offered by them which may be of interest to You;
- by inviting You to participate in their surveys;
- for other advertising, statistical compilation or
marketing-related purposes; or
- by responding to Your requests,
- unless You have informed us that You do not wish
to receive any Business Partner Communications in accordance with Clause 5.3.
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We may also be required to disclose Your Data in the following
circumstances:
- to comply with a legal process;
- to enforce the general Terms and Conditions, this Privacy Policy or any
other agreements executed with You or any related entity;
- to protect Your rights, Your property or personal safety and/or the public, or
to protect the business operations of Application ;
- where applicable, to credit reference agencies, where Your Data may be
used by other credit grantors for the purposes of:
- (making credit decisions about You and the people with whom You are financially associated with;
- fraud or money laundering prevention; and
- occasionally, for tracing debtors.
Accordingly, Your Data will be disclosed where we are obliged or permitted
by law to do so. If You post or send offensive or objectionable content to us or
otherwise engage in any disruptive behavior in respect of Application, we can
use whatever Data that is available to us about You to stop such behavior. This
may involve informing relevant third parties such as Your employer and law
enforcement agencies about the content and Your behavior.
CONSENT AND OPTING-OUT
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By submitting or providing Your Data to us, You expressly acknowledge,
consent and agree to:
- our use or processing, or the disclosure to, or use or processing by,
Authorised Representatives, of Your Data, including any Personal Information
contained in your Data, for the purposes described in Clauses 3.1 and 3.2;
- subject to Clause 5.3, the use or processing of Your Data, including any
Personal Information contained in Your Data, for the purpose of sending You any
Communications; and
- subject to Clause 5.3, the use or processing by our Business Partners of
Your Data, including any Personal Information contained in Your Data, for the
purpose of sending You Business Partner Communications.
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We follow strict security procedures to ensure that Your Data is protected. All
Data is kept in a secure place with restricted physical or electronic access, and
shall remain confidentially. Only Our senior management team is permitted
access to the Data. Notwithstanding the aforesaid, You expressly acknowledge
and agree:
that the transmission of information via the internet is not completely secure. We
will do our best to protect Your Data but we are unable to guarantee the security
of Your Data submitted or provided through or in connection with our Application,
and accordingly, any submission or provision of Data is made at Your own risk
and with no responsibility upon Nejoud; and
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You may inform us by an email to [email protected] if You wish to
exercise Your right to opt out of receiving any Communications from us or from
our business partners. If You do opt out, this may preclude You from receiving
any of our special offers or promotion, whether offered by us or by any Business
Partner.
RETAINING AND DELETING DATA
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Upon termination of Your access to Application in accordance with the
general Terms and Conditions, we may still be required to retain Your Personal
Information or Data in order to comply with legal obligations, prevent fraud,
collect fees owed (if any), resolve disputes and troubleshoot problems etc, but
always done within a legal framework.
- When You request for Your Data to be removed in accordance with Clause
- You will be added to a suppression list to ensure Your request is complied
with.
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INFORMATION REQUESTS
Unless the Personal Information relates to an individual which You are legally
responsible for (such as a minor of less than 21 years old), You may not give us
Personal Information about any other person. If You do so, You confirm that they
have appointed You to act on their behalf legally, and to consent to the
processing of their Personal Information, including sensitive personal data, to the
transfer of their Personal Information abroad and to receive on their behalf.
It is also understood that provision of Personal Information relates to an
individual will be under Your own risk and responsibility and You shall keep
Nejoud fully harmless and indemnified against any respective liability.
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COOKIES
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If You use our Application, our computer server may automatically send You
a cookie. A cookie is a small 'log-file' that can be placed on Your computer's hard
disk for record-keeping purposes and we may use them to do a number of things:
- cookies help us to recognize You when You next use our Application and
note the advertisements displayed to You. This allows us to tailor the promotions
we provide to Your preferences. We may use the services of third party servers
for this purpose;
- cookies may be used to compile anonymous statistics related to the take
up or use of the services, or to patterns of browsing. A third party may collect
such data on our behalf to measure the performance of Application. Information
collected is aggregated for reporting purposes, and no personally identifiable
information is collected by this service. The use of this service assists us in
measuring and improving the structure and ease of use of Application;
- we may also track IP addresses. An IP Address is a number that can
identify an Internet Service We, country location etc. It cannot provide personal
information. We will not use the IP Address to build a profile on You; we only use
the information for demographic and statistical purposes.
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It is also possible that others may download cookies to Your Application
when You access, visit or use the Application.
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MODIFICATION OF PRIVACY POLICY
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This Privacy Policy may be modified from time to time as a result of any
changes in the law, best practice and/or in the Application with one week notice
to You. The most current version of this Privacy Policy as posted on this page
shall supersede all previous versions.
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It is Your responsibility to check regularly to determine whether a new
version of the Privacy Policy has been uploaded.
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QUESTIONS
If You have any questions about this Privacy Policy, or Our privacy practices,
You can email at [email protected]