Privacy Policy

Qanooni AI Ltd and/or its affiliates and entities (collectively "Qanooni", "we", "our" or "us") values your security and privacy. Qanooni is required to comply with DIFC Authority's Data Protection Law, DIFC Law No. 5 of 2020 (the "DP Law"), and may for certain types of personal data processing, be subject to laws of other jurisdictions.

It is the policy of Qanooni to respect the privacy of those visiting its website and/or using its products and services, including Qanooni's mobile applications (the "App"). Qanooni collects information about you when you use or access our websites, use Qanooni email addresses for contact purposes, or you avail of our products, information or services (collectively, the "Services") as well as through other interactions and communications you have with us.

By providing your personal data to us (whether via one of our websites, by email or other electronic means, in person or over the phone), you agree to the processing set out in this privacy policy (as amended or supplemented from time to time) (the "Policy"). In the Policy, the term "Personal Data" means any information which refers to (i) an identified person or (ii) a natural living person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to their biological, physical, biometric, physiological, mental, genetic, economic, cultural or social identity.

The Policy sets out the basis on which any information, including any Personal Data, we collect from you, or you provide to us, will be processed by Qanooni. Each time you access or use our website, Services or the App or provide us with information, by doing so you acknowledge and consent to the practices described in the Policy. For use of specific services, you may be asked to opt-in to or otherwise consent to our use of certain information you submit in connection with those services either through separate opt-ins, consents or through the applicable Qanooni user terms or other agreement between you and Qanooni (the "Qanooni Agreement"). Your rights described herein apply in such instances, as supplemented or amended by the relevant opt-in, consent or Qanooni Agreement.

1. Scope and Application

The Policy applies to persons anywhere in the world who access or use our website, Services or the App (collectively "you", or "your").

The Policy applies to your use of our services and all information we collect through our services. By accessing and using Qanooni's website, Services or the App, you (i) agree irrevocably and without condition to the Policy, (ii) consent to your Personal Data being collected, processed, used and shared in accordance with the Policy, and (iii) agree that we may provide notices to you electronically on the terms and conditions set forth in the Policy and any applicable Qanooni Agreement.

It is important that you read the Policy together with (i) any fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you and (ii) any relevant Qanooni Agreement, so that you are fully aware of how and why we are using your Personal Data. The Policy supplements the other notices and any applicable Qanooni Agreement and is not intended to override them.

2. Collection of Information

Information you give us

The Qanooni website, Services and App collect and process Personal Data in accordance with the DP Law and applicable laws, including for specific, lawful purposes explained herein or at the time of collection, or for the performance of tasks carried out in your interests or the legitimate interests of Qanooni. Such collection and processing may occur in relation to the following:

• To enable you to set up a Qanooni account;
• To assist you with using the Qanooni services;
• To provide you with any Qanooni products, services and features you wish to use;
• To identify and fix errors that impair the functioning of our services;
• To attend to any questions or complaints you may have;
• To send you surveys and collect your feedback or to send you information we think you may find useful or which you have requested from us about our services. For avoidance of doubt, you agree that we may communicate with you in a number of ways for the purpose of collecting your feedback, including through the website, Services or App, by email, telephone, WhatsApp or through other digital channels. Please contact us at sales@qanooni.ai if you wish to withdraw your consent to receive communications from us seeking feedback;
• To provide, maintain, improve, personalise and facilitate our services, content, products and features;
• To develop new products and services (such as machine learning based tools) to better serve you;
• To track and analyse usage in connection with your use, or the performance, of our services;
• To issue reports/analytics on a no name basis for business and marketing purposes;
• For any other purpose for which you provide us with your Personal Data;
• To meet our compliance and regulatory obligations, enforce any applicable laws, regulations, legal requirements, and industry standards and to respond to lawful requests for information from the government or in relation to any legal process, including tax authorities or any competent court or legal authority;
• To administer and manage our business, including recovering any money you may owe to us;
• To seek advice on our rights and obligations, such as where we require legal advice;
• To resolve disputes;
• To investigate, detect, prevent, recover from, or report, fraud, misrepresentations, security breaches or incidents, other potentially prohibited, malicious, or illegal activities, or to otherwise help protect your account;
• To protecting your, our, or our other users' rights or property, or the security or integrity of our website, Services or App; and
• To verify or maintain the quality and safety of our website, Services or App.

If you contact us, we will keep at least an electronic record of such correspondence, including personal information shared at that time, in order to reply or process it as per your request. The personal information you give us may include your name, address, e-mail address and phone number, certain device information, username, password, residential building, work address, photograph, and other information you choose to provide.

Please keep us informed and updated if your Personal Data changes during your relationship with us. If you have opened an account with Qanooni to access specific services ("Account"), depending on the type of Personal Data in question, you may be able to review and update your Personal Data in the settings applicable to your Account by logging in to your account or by contacting us at sales@qanooni.ai.

Our website, Services and App are not targeted, intended, or expected to be of use to children. Apart from providing information for specific services or purposes, as directed by Qanooni processes, your contributions of content or contact information regarding or about children are expressly prohibited.

Information we collect about you and your device

Each time you use our website, Services or App we may and often will automatically collect the following information:

• technical information, including the type of mobile or other device you use, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, time zone setting ("Device Information"));
• details of your use of our website, Services or App including, but not limited to traffic data, weblogs and other communication data, and the resources that you access ("Log Information");
• location information where our website, Services or App uses GPS technology to determine your current location. If you wish to use certain features, you may be asked to opt-in to your data being used for this purpose.

If you do not wish to share certain data with us or do not want us to use / share it for certain purposes (to the extent possible, in accordance with applicable laws and information in this notice), you can alter your preferences at any time. Where applicable, please check with your device provider's instructions for further information about how to do this.

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that Personal Data when requested, we may not be able to perform certain services for you. If this happens, we may have to cancel the services available to you - we will notify you if this is the case at any time.

In certain circumstances, we may obtain information about you from publicly available sources or from third parties, most commonly where we need to conduct background checks about you. This may include third-party verification services.

Other Information We May Collect Through Your Use of our website, Services or the App

When you use our website, any Services or the App, we may collect Personal Data including demographic information, for example information that you submit, or that we collect, which may include, but is not limited to, post code, age/birth date, current residence, hometown, gender, username, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, device location, IP address, SMS data, transaction information, business activities and services / distribution locations, browsing history information, searching history information, and registration history information.

3. Use of Personal Data

We may use Personal Data which you provide to us or we collect from you to:

• Provide, maintain, and improve our website, App and Services, including, for example, to provide products and services you request (and send related information about them), develop new features that will enhance your user experience and our efficiency, provide customer support, authenticate users, and send administrative messages, whether information-only or required by applicable law;
• Perform internal regulatory, administrative and operational requirements, including, for example, to prevent fraud or abuse of our website, Services or the App; to troubleshoot software bugs and operational problems; to conduct permitted data analysis, testing, and research; to ensure you and Qanooni are complying with internal or external legal requirements, including those that necessitate use of digital systems; and to monitor usage and activity trends;
• Send you communications we think will be of interest to you based on your previous interactions with us, including information about products, services, promotions, news, and Qanooni events, where permissible under applicable law applicable laws; and to process contest, sweepstake, or other promotion entries and fulfil any related awards;
• Notify you about changes to the Policy, or our website, App and Services;
• Allow you to participate in any interactive features of our website, App or Services;
• Keep our website, App and Services safe and secure; or
• Personalise and improve our website, App and Services, including to provide or recommend features, content, social connections, referrals, and advertisements, in accordance with your preferences, to the extent permissible by law.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data as this data does not directly or indirectly reveal your identity.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the Policy, where this is required or permitted by law.

4. Processing, Storage and Transfer of Personal Data

We will take all steps reasonably necessary to ensure your Personal Data is processed fairly and lawfully, in accordance with the DP Law, other applicable laws and the Policy. By submitting your Personal Data, we expect you to understand that such transfer, storing or processing in order for Qanooni to perform its general administrative functions is necessary and will be done in a proportionate, lawful manner, including but not limited to responding to enquiries you raise via our website, App or Services, oversight of the business entities registered in DIFC's jurisdiction and maintaining contacts for future informational or promotional activities. Unless otherwise notified, Qanooni does not ordinarily rely on automated decision making when processing your Personal Data in connection with the Services or accessing the App.

In order to conduct our operations or fulfil regulatory obligations, we may transfer the Personal Data described in the Policy to and from, and process and store it in, the United States of America and/or United Arab Emirates and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those of the DIFC or where you reside. In all such cases, and generally for any processing operations, we take appropriate security measures to protect your Personal Data in accordance with the Policy. Please see section 7 below and any applicable Qanooni Agreement for further security related information. By continuing to access the Website and any applicable Qanooni service, you consent to data transfers and processing on the basis set out in the Policy.

To preserve the integrity of our databases, to carry out on-going Services or provide our website or App, for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations, we retain Personal Data submitted by you for a reasonable length of time unless otherwise prescribed by applicable law.

Qanooni is not responsible for the accuracy of the information you provide, and will modify or update your Personal Data in our databases when you provide updated information or ad hoc upon your request, as further outlined below. We will erase or put beyond active use your Personal Data upon request, unless we are required or permitted to retain it in accordance with applicable laws or to perform agreed services. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

By accessing or using our website, App or Services, we can reasonably expect that you understand that all information submitted by you through our website, App or Services or otherwise to Qanooni may be used by Qanooni to support these processing operations, in accordance with applicable laws and its policies.

5. Sharing of Personal Data

Through Our Website, Services or the App

We may share Personal Data which we collect about you as described in the Policy or as described at the time of collection or sharing, including as follows:

• With third parties to provide you with a service that you requested through a partnership or promotional offering made by a third party or us; or
• With third parties with whom you choose to let us share your Personal Data, for example other apps or websites that integrate with our website, App, API or Services, or those with an App, API or service with which we integrate.

Other Types of Data Sharing

We may share your Personal Data:

• With Qanooni subsidiaries and affiliated entities, to the extent permissible by law;
• With vendors, consultants, marketing and advertising partners, and other service providers who need access to such Personal Data to carry out work on our behalf or to perform a contract we enter into with them;
• If we otherwise notify you and you provide your affirmative opt-in or consent to share your data, where needed;
• With third parties in connection with, or during negotiations of, any merger, sale of Qanooni assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another Qanooni; or
• With third parties in an aggregated and/or anonymized or pseudonymized form that cannot reasonably be used to identify you

Government Data Sharing

In some circumstances we are legally obliged to share information with public authorities or law enforcement. For example, we may be required to provide information related to a court order or where we must cooperate with supervisory authorities in handling complaints or investigations. In any scenario, we'll attempt to satisfy ourselves that we have a lawful basis on which to share the information, document our decision making, and satisfy ourselves we have a legal basis on which to share the information.

We may also share information in the event of the non-payment including of a monetary penalty or court ordered costs. If the debt remains outstanding after the specified timeframe for payment, no payment plan is in place or an agreed payment plan is not being adhered to, we may initiate formal proceedings to recover the full amount of the unpaid penalty. In such cases, Qanooni may share Personal Data with the litigation and recovery specialists it instructs in order for them to identify assets and undertake recovery action as it sees fit, including through the courts.

6. Your Rights and Choices

Marketing and Preferences

Qanooni supports your legal rights to opt-in or subsequently opt-out of receiving communications from us and our partners. You have the option to ask us not to process your Personal Data for marketing purposes and to remove it from our database, to not receive future communications or to no longer receive our App or Services. You may change your preferences at any time by emailing us at sales@qanooni.ai.

Please note that we may continue to send you transactional or service-related e-mails despite your desire to not receive promotional or marketing e-mail messages. Additionally, please note that if you elect to opt-out of or unsubscribe from receiving promotional or other similar e-mails or messaging from one of our Services or the App, you may continue to receive promotional emails from our other websites, providers, or other, non-affiliated marketers whose services you may have accessed via Qanooni Services or App.

Finally, while we may remove your individual contact information from our professional contacts database, please be aware that if such information is in a different, third party's marketing directory through your request or election, you will need to contact such third party directly to request removal.

Your rights

You may have certain rights under the DP law in relation to your Personal Data, including the right to receive information about the Personal Data being processed, the right to request transfer of Personal Data, the right to correction or erasure of Personal Data, the right to withdraw consent, the right to correction or completion of inaccurate Personal Data, the right to restrict Personal Data processing, and the right to object to Personal Data processing.

This right of access can be exercised for any reason, at any time, in accordance with the DP law and other applicable laws. Any access request generally comes at no cost to you and we must respond within one month unless provided otherwise by the DP Law or other applicable laws. We may, where permissible, impose a reasonable fee to meet any extraordinary administrative costs in providing you with details of the information we hold about you.

If you withdraw your consent to the treatment of your information, any such withdrawal will not affect any processing of that information prior to withdrawal of your consent or any processing which is in line with, or required by, applicable law.

You may also request that we restrict the processing of, erase, transfer the information you gave us from one organisation to another, or otherwise process your Personal Data in line with the relevant articles providing for such rights set out in the DP Law or other applicable laws.

When you contact us about a potential Personal Data error or query, we will endeavour to confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry. We will endeavour to send a correction notice to businesses or others whom we know to have received the inaccurate data, where required and / or appropriate. However, some third parties and third party sites may continue to process inaccurate data about you until their databases and display of data are refreshed in accordance with their update schedules, or until you contact them personally to ensure the correction is made in their own files.

We will not discriminate against you for exercising your rights under the DP Law by denying services or changing prices or quality of service, unless it is reasonable for us to do so, as objectively determined by us.

7. Security Precautions

Qanooni makes every effort to ensure that your Personal Data is secure on its system. Qanooni has staff responsible for maintaining our data protection and security policies, periodically reviewing them and making sure that Qanooni employees are aware of our data protection and security practices. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, Qanooni cannot warrant or guarantee the security of any Personal Data you transmit to us, and you do so at your own risk.

Qanooni has established policies and procedures for securely managing information and protecting Personal Data against unauthorised access. We continually assess our data privacy, information management and security practices. We do this in the following ways:

• Establishing policies and procedures for securely managing information;
• Limiting employee access to viewing only necessary information in order to perform his or her duties;
• Protecting against unauthorised access to Personal Data by using data encryption, authentication and virus detection technology, as required;
• Requiring service providers with whom we do business to comply with relevant data privacy legal and regulatory requirements;
• Monitoring our websites through recognised online privacy and security organisations;
• Engaging in regular third party audits of our policies and practices; and
• Conducting background checks on employees and providing training to our employees.

If you have any further questions about our security and processing activities, please contact the Qanooni team. To the extent permitted by applicable law, Qanooni expressly disclaims any liability that may arise should any third parties obtain the Personal Data you submit through fraud or otherwise where it is no fault of Qanooni.

8. Cookies

A cookie is a small text file that is unique to the web browser on your computer or mobile device, which is used to retain user preferences, and enhance browsing experience ("Cookie"). Qanooni uses Cookies to track overall site usage and enables us to provide a better user experience. We do not use Cookies to "see" other data on your computer or determine your email address.

Most browsers accept and maintain Cookies by default.

On our website, we use necessary cookies to operate the site, plus analytics and marketing cookies to understand how the site is used and to measure our marketing. When you first visit the website you can accept or decline non-essential cookies via our cookie banner, and you can also change your Cookie preferences in the 'Help' or 'Settings' menu of your browser. Altering Cookie settings may limit your ability to access certain areas of the website, Services and App.

While we set some of these automated technologies ourselves, some of them are set by third parties who provide services to us. On our website these include Google Analytics and Google Ads, Meta (Facebook), LinkedIn, HubSpot, Microsoft Clarity and Snitcher, which use automated technologies to help us evaluate how our users use our website and how our marketing performs.

Alternatively you may wish to visit an independent source of information, such as www.aboutcookies.org, which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual or network operator for advice.

9. External Links

The Website and the App may contain links to other websites on the Internet that are owned and operated by third parties (the "External Sites"). These links are provided solely as a convenience to you and not as an endorsement by Qanooni of the contents of or reliability on such External Sites. You acknowledge that Qanooni is not responsible for the availability of, or the information and content of any External Site. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or the content located on such external Sites.

If you decide to access linked third party websites, you do so at your own risk. Qanooni does not accept liability, and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the content of another website to which you may link from our website, Services or the App.

10. International Data Transfers

We may transfer and process your personal data in countries outside your country of residence, including to countries that may not have the same data protection laws as your jurisdiction.

Whenever we transfer personal data internationally, we ensure appropriate safeguards are in place. For users in the European Economic Area (EEA), this means we rely on the European Commission's Standard Contractual Clauses (SCCs) when personal data is transferred outside the EEA.

We use the following trusted third-party service providers who may process your data:

We review our data transfer safeguards regularly and remain committed to protecting your personal information.

You may request further information or copies of applicable SCCs by contacting us at ziyaad@qanooni.ai .

11. Buildings Security and Contents

Building security records containing sign in and sign out information collected at the time of visiting and departing Qanooni offices will be maintained in accordance with the applicable building management policy.

To the extent permitted by applicable law, Qanooni is not responsible for any contents, whether or not they contain Personal Data or other business information, that remain in our premises after you leave Qanooni offices.

12. Changes to the Policy

Qanooni may change the Policy from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Policy, we will endeavour to provide you notice through our website, App or Services or by some other means, such as email. Your continued use of our website, App or Services after such notice constitutes your understanding of and agreement to the changes. We encourage you to periodically review the Policy for the latest information on our privacy practices. We provide links to it through:

• Our website, App or Services
• Referencing it in any applicable Qanooni Agreement
• Incorporating it into our contracts, agreements, and other documents as necessary or appropriate

Contact Us

If you have any questions, comments and requests related to the Policy, or if you have any complaints related to how Qanooni processes your Personal Data, please contact:

Phone: +971 56 913 7055
Email: ziyaad@qanooni.ai

You may also contact the DIFC Commissioner of Data Protection's Office at:

Dubai International Financial Centre Authority
Level 14, The Gate Building
Phone: +971 4 362 2222
Email: commissioner@dp.difc.ae