Privacy Policy

PRIVACY AND DATA PROTECTION POLICY

Last modified:  16 February 2021

Effective date:  17 February 2021

This Privacy and Data Protection Policy (“Policy”) is effective as of the date set forth above. Had Telecommunication & IT Co. (“Company”, “Had Telecommunication & IT Co.”, “We”, “Us”, “Our”), operating with Teach Me Arabic project, is committed to honoring and encouraging the protection of your privacy (both users who are registered (“Users”), and visitors, who operate without registration (“Visitors”)).

This Policy applies to every individual whose personal data is collected by the Company through the App and other persons whose personal data is lawfully disclosed to and processed by the Company (“Data Subjects”). This Policy describes how We collect and use the personal information you provide Us with through your use of the App (“App”).

Be attentive while disclosing your sensitive personal information (e.g. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of genetic data, health, your sex life or sexual orientation) (“Sensitive information”) to other Users through the App!

You may print a copy of this Policy for your records.

We act as a Data Controller

We act as a data controller, that is, a legal person that determines the purposes and means of the processing of personal data, with regard to personal data of Our App Users and Visitors. Questions, comments and complaints about Our data practices can be submitted to the following address:

Had Telecommunication & IT Co. (Reg. No. 1010600882).

Address: Al-Rabie District, Riyadh,13315 Saudi Arabia;

Phone number: 00 966 11 263 0374

Email address: terms@teachmearabic.org ;

Director Amin B. Al Zahrani

Data We Collect

We collect different categories of personal data for Visitors and Users of Our App. If you visited the App with or without any purpose and did not fill in the registration form, you instantly become a Visitor.

Should you want to continues to use the App after trial period you need to fill in the registration form and acquire a User status.

Information created when you visit Our App is:

  • OS type and version;
  • Device information and screen size.
  • Time, locations, time zone and language preferences.

We use this information to make the functionality of Our App available to you, enable you to use the third-party services, to enhance Our App, and answer any question or queries you may have.

Information We may ask you as a User to provide Us with

You do not have to fill in the data mentioned above. However, profile gets you an opportunity of richer experience from Our App. We treat the information as true data about you. We use these data in order to identify you and confirm your persona, facilitate the communication on the matter of self-study mechanism to foster hopeful teaching of the Arabic language to non-speakers.

We may collect the following information about you as a User:

  • identifiers: email address, full name, age, descripted password.
  • commercial information: none
  • biometric information: fingerprint, faceprint screen lock, PIN, pattern and password.
  • internet or other electronic network activity information: OS type and version, device information and screen size.
  • geolocation data: Time, locations, time zone and language preferences.
  • audio, electronic, visual, thermal, olfactory: mic and camera accesses.
  • professional or employment related information:  none.
  • education information: learning goals, use purpose, learning progress including passed and unpassed levels, units, sessions and activities.  

 

Remember, We do not run any automated decision-making devices or software including those based on all the data aggregated. We do not use personal information We collect for profiling.

Cookies and Third-Party Technologies

The Company and its partners use cookies and other identification technologies on Our App for purposes described in this notice.

Cookies are small text files that are stores on devices by apps. Cookie may contain your unique identifier and typically serve to improve your experience of Internet surfing: for instance, due to cookies, you are able to browse pages you have once visited quickly, to set your unique options in “settings” menus, as well as monitor your way through the webpages in order to aggregate precise information about your navigation and preferences, so the app owners may analyze the information and offer you a better service and relevant ads in the future.

You may learn more about cookies We use in Our Cookie Declaration.

Why We use cookies /tokens

We implemented cookies on the App for a few reasons:

  • To verify your persona (your account on the device) and help prevent identity theft or other fraudulent use of credentials;
  • To ensure your good experience while using Our App, for instance:
    • remembering user preferences and settings;
    • authenticating users;
    • determining the popularity of content;
    • analyzing app traffic and trends, and generally understanding the online behaviours and interests of users who use Our App;
  • To analyze the way the App is used and accessed (your clicks, time you spend for tasks completion) etc.
  • To secure the use of the app and let only the authorized person to use it .

Our Partners

Some of features are not developed by Us but embedded on Our App by Our partners and are not used by Us to collect your data or provide services to you on Our own behalf. Strictly speaking, some services you can obtain access to via Our App are part of Our partner’s sites or apps and are placing the cookies (and collecting your personal data through them, if you provide them with such personal data) themselves.

Cookies of Our partners are subject to such partners’ privacy policies.

Service of One Entry

You can log into Our App via various login services, such as Facebook Connect or Google account. These services will identify your identity and allow Us to share certain personal information (e.g. your name and email address) to automatically fill out Our registration form or verify you.

How We Use Personal Data

Our Purposes

Our App is aimed at providing you with educational and other services, according to Our Terms of Use. Thus, We need your data to provide you with the respective services.

As We mentioned in Data We Collect, We will use your personal data for the following purposes:

Preform the learning services mentioned in the term of use conditions;

Send notification regarded to app use and learning progress;

Improve the provided services and upgrade the user experience.

 

Processing personal data for marketing purposes

Where you have opted in to receive marketing communications from us, We will process your personal data to provide you with marketing communications in line with the preferences you have provided.

The legal basis on which We process your personal data for marketing purposes is your consent. You are not under any obligation to provide Us with your personal data for marketing purposes, and you can withdraw your consent to your personal data being processed in this way at any time by contacting Us at email address, via telephone number or via online form in any marketing communication you receive from us. If you do choose to withdraw your consent, this will not mean that Our processing of your personal data before you withdraw your consent was unlawful.

Disclosure of Your Personal Data

We ensure We always include the controls and warranties embodied in this Policy to the contracts and agreements. We enter into with Our partners and contractors whom We grant access to your personal data to.

Grounds for Processing

We promise that We use the personal data we’ve obtained from you or on your behalf in a way that does not outweigh your rights and freedoms.

Despite this, We must comply with the GDPR and CCPA requirements to the legal grounds for processing. The GDPR and CCPA allows Us to collect and process your personal data on the legitimate grounds as follows:

The processing is necessary to provide you with the Services and features available through Our App

To achieve this purpose, We may need Your account information.

The processing is necessary to fulfill Our legal obligations

GDPR as well as other applicable laws depending on the relationship between you and Our company may affect:

  • the scope of personal data We collect;
  • ways We process your personal data in;
  • our ability to keep the confidentiality of your data and avoid their disclosure;
  • duration of the planned retention, etc.

Where processing is necessary to protect the vital interests of individuals or public policy, We cannot refuse to provide the copies of your personal data We have collected or may have access to within the functionality of the App to the authorities and enforcement agencies in case of receipt of their legitimate decision or demand to do so.

Also, We may be obliged to provide the aggregated information to the state statistics bodies or to state historical archives.

The processing is necessary to secure Our or third parties’ legitimate interests

We may use the personal data We collect and process (including yours) in order to maintain and enhance Our user’s safety and security (for instance, We use cookies in order to prevent fraudulent use of credentials), enabling or administering Our business (quality control, consolidated reporting, customer service), transfer of ownership and so on.

Also, We may report to the police or other competent enforcement agencies in case We discover fraud, threats to other users or any other violations of the applicable law or suspicious behavior or actions committed on behalf of your account.

Pursuant to and as limited by your consent

Among the purposes We list above, We rely on your consent when We use your personal data (for instance, your experience of interaction with Our App as caught and stored via the cookies) for optimizing and enhancing the operation of the App, developing new features and services (including when it is collected as a part to the aggregated data), and providing you with relevant marketing materials as long as it is allowed by your device.

Your Age

Before using Our Services, you have to reach the age of sixteen (16). We do not normally provide services to subjects under the abovementioned age. Subsequently We do not process their personal data. We reserve the right to implement any tools and techniques to reveal the human trafficking and exploitation of children, and report them immediately to the appropriate state authorities and enforcement agencies, including the personal data associated with the activities which, at Our own discretion, are suspicious and may raise concerns about their association with the violation of applicable laws.

By using or accessing Our App, We believe that such Data Subjects are at least sixteen (16) years old and have all rights to enter into an agreement with Us as to the receipt of Services and use of App, as well as collect and process personal data under Data Subjects’ consent for the purposes We mention in this Policy.

If you know that We process personal data of User under sixteen (16) years old, please inform Us by sending email at terms@teachmearabic.org or via telephone number 00 966 263 0374.

Retention of Personal Data

We will store and process your personal data for as long as your account is active or for as long as needed to provide you or Our users with the Services. In case your account is not active anymore, the personal data will not be stored longer than one (1) year from the moment of its last activation. Some cookies data might be stored longer. Its retention period you might find at Cookie Declaration.

After expiry of a year retention period We are to delete your personal data, unless its storage is justified by legal obligation or Our legitimate interest to do so (i.e., your account has been previously noticed or suspected in participation in the fraudulent schemes, botnet, etc.).

Where We have processed your personal data to provide you with marketing communications with your consent, We may contact you at least every twelve (12) months to ensure you are happy to continue receiving such communications. If you tell Us that you no longer wish to receive such communications, your personal data will be removed from Our list.

Deleting your account will automatically entail deletion of your data, unless its storage is justified by legal obligation or Our legitimate interest to do so (i.e., your account has been previously noticed or suspected in participation in the fraudulent schemes, botnet, etc.).

You may also solely delete your account under its settings, or request deletion of your account at any time by sending Us an email at contact terms@teachmearabic.org  or via telephone number 00 966 11 263 0374, or via special online form of withdrawal. Executing your request, We will delete your account within thirty (90) days. Sometimes We may be unable to delete your account or personal data (for instance, in case of unsettled or unresolved dispute or claim, or in case We suspect you in being associated with a crime or other violation of applicable law, e.g. fraud, unsafe behavior, security incident). Upon the resolution or settlement of claim, conclusion of a criminal or administrative proceeding, or learning that Our suspicion is unjustified, We will delete your account or personal information.

State authorities, enforcement agencies, courts

We may be legally obliged to disclose your personal data to the competent state authority, enforcement agency or a court in case We receive a mandatory request for such disclosure from them.

As We warned you earlier, We may be proactive and address the competent authority in case We suspect a violation of law to be committed in association with your account or persona via Our App.

Your consent

We will notify you of the purposes and scope of the disclosure and ask for your permission in case your personal data is to be shared with a third party not mentioned in this Policy.

Right to Withdrawal of Consent

You have a right to withdraw consent to processing of your personal data.

You may enjoy this right at any time you wish. Please remember, that the withdrawal of consent does not mean that the processing before the withdrawal is considered thus illegal.

You may withdraw your consent by deleting of your account, sending Us an email to [insert email] or via telephone number [insert phone number] as well as through online form of withdrawal. Before withdrawing your consent, take into attention the outcome such withdrawal may entail.

We will do Our best to verify your withdrawal of consent within seventy two (72) hours since the receipt of your request.

Cross-border Transfer of Data

Our headquarters is in Saudi Arabia. We make every effort to protect entrusted data against unauthorized access. The procedures applied, such as a comprehensive access authorization system and technical security measures, are regularly reviewed and adapted to technical progress. The secure transmission of user data via SSL encryption which ensures reliable data protection.

We also may use support from the specialists skilled in performing tasks to enhance our Services as well as other independent contractors, e.g. IT specialists, accountants, auditors, lawyers, etc, provided that all adequate safeguards are put in place.

In order to secure the adequate level of protection, We implemented the Standard Model Clauses as well as signed Data Processing Agreements in the relationships with the engaged contractors, so they are bound to preserve at least the same level of personal data protection as it is granted by the law applicable to us.

Your Rights

There is a scope of rights you may enjoy as to personal data protection with regard to GDPR and CCPA.

The list of rights protected under GDPR is as follows:

  • right of access (i.e. you may ask Us to send you a copy of the data about you that We collected);
  • right to rectification (i.e. you may ask Us to correct the outdated or false data, or complete the data which is missing or incomplete)
  • right to erasure (i.e. you may ask us to delete the personal data We retain, provided that you are allowed to do so);
  • right to restriction of processing (if processing may be restricted)
  • right to object to processing (if you have a right to object as to certain kinds of processing or in certain circumstances)
  • right to data portability (i.e. you may ask Us to transfer a copy of your data to another organization or to you provided that the circumstances comply with the data protection law).

The list of rights protected under CCPA is as follows:

  • the right to request that a business that collects a consumer’s personal information disclose to that consumer the categories and specific pieces of personal information the business has collected;
  • the right to request that a business delete any personal information about the consumer which the business has collected from the consumer;
  • the right to request that a business that sells the consumer’s personal information;
  • the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information (“Right to opt-out”).

 

Please remember that We do not charge any fees in relation to exercising your rights (unless We receive repetitive requests without a clear justification behind the need to request the information within such short periods of time; in this case, We may charge you a small fee to compensate the expenses that incur due to the repetitive and excessive character of requests). We typically do Our best to answer you as soon as possible or within the reasonable period taking into account the complexity of the request, but in case We are processing a large amount of requests the answer may took Us longer than you might expect.

You can send Us the request via email or via telephone number. Please verify that your request comprises the details:

  • your name;
  • contact information;
  • right you want to exercise, and, where applicable;
  • your personal data in Our processing;
  • reason/justification behind such request.

We may ask you to provide Us with some information We already have to verify that it is you or holder of parental responsibility on your behalf.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct Us to not sell your personal information at any time. We do not sell the personal information of consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to Us by sending Us a message via email terms@teachmearabic.org or via phone number 00 966 11 263 0374.

 

Once you make an opt-out request, We will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting Our App and sending Us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

Complaint Lodgment

In case you are convinced We are somehow infringing your personal data rights granted by the GDPR, you may lodge a complaint with the supervisory authority. Our lead authority is:

Name: Had Telecommunication & IT Co. (Reg. No. 1010600882).

Address: Al-Rabie District, Riyadh,13315 Saudi Arabia;

Phone number: 00 966 11 263 0374

Email address: terms@teachmearabic.org ;

 

We would also like to inform you that We do not have EU Data Representative, a natural or legal person based in EU, whom the EU or relevant GDPR supervisory authorities can contact for any issue related to data processing. In case We will be obliged under the GDPR to appoint Data Representative to be in compliance with privacy law, We will update this Policy with all the necessary information as to regard to this matter.

We kindly invite you to share your concerns with Us first. You may use the following channels to address your inquiries:

Email address: terms@teachmearabic.org ;

Telephone number: 00 9666 11 263 0374

Updates to the Policy

We may occasionally update this Policy.