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Data Privacy Policy
Last updated: 2nd June 2021
Your privacy is extremely important to us.
This Data Privacy Policy informs you about how we collect, use, disclose, manage and protect any personal data you provide to us when accessing or using our website with URL https://www.hakkini.com , as well as any other media form, media channel, mobile website or mobile application related, linked, or otherwise connected thereto (collectively, the “Site”), what we do with it and how you can control what personal data we collect from you. It applies to any individual visiting or using the Site including specialists that provide specialist services
Please read it carefully.
Unless defined otherwise, all definitions included in our Terms of Use will apply to this Data Privacy Policy.
Who We Are and How to Contact us
The Site is owned and operated by Hakkini FZ-LLC, a limited liability company established in Dubai Internet City with commercial license number 97272 (“Hakkini” or “We”).
Applicable Terms and Consent
When you access or use the Site, or otherwise provide any personal data to us, you agree to this Data Privacy Policy, including the manner in which we use your personal data. If you do not agree to this Data Privacy Policy, or to any changes we subsequently make to this Data Privacy Policy, you must immediately stop using the Site or otherwise providing any information to us.
Further, we reserve the right to change, in our sole discretion, the terms of this Data Privacy Policy at any time by publishing the varied terms on the Site, with or without notice.
You are responsible for reviewing regularly information posted online to obtain timely notice of such changes. As such, we recommend that you check the Site regularly to ensure you are aware of our current terms. We do not undertake to keep our Site up-to-date and we are not liable if any content is inaccurate or out-of-date. Your continued use of the Site after changes are posted constitutes your acceptance of the Data Privacy Policy as modified by the posted changes.
Regardless of later updates or changes to our Data Privacy Policy, we will never use the information you submit under our current Data Privacy Policy in a new way without first providing you an opportunity to opt-out or otherwise prevent that use.
Age of Consent and Third Party Services
The Site is intended for users who are at least 18 years old. Persons under the age of 18 are not permitted to register for the Site. All users who are minors in the jurisdiction in which they reside (generally under the age of 18) must have the permission of, and be directly supervised by, their parent or guardian to use the Site. If you are a minor, you must have your parent or guardian read and agree to this Data Privacy Policy prior to you using the Site.
You need to create a Hakkini account to access and use the Site and in doing so, you must provide us with accurate and complete information as prompted by the registration process.
We may allow you to log in to the Site through various online third-party services, such as social media and social networking services like Google, Facebook or Twitter (“Third Party Services”). In order to use these features and capabilities, we may ask you to authenticate, register for, or log into Third Party Services on the websites of their respective providers.
Third Party Services use, store, and disclose your information solely in accordance with their own policies. We assume no responsibility or liability for the privacy practices or any other actions of any third-party website or service that may be enabled within our services or of which a link is included on the Site. Further, we assume no responsibility or liability for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such Third Party Services.
Personal Data We Collect
To let us operate the Site effectively and to let you use the Site, including allowing you to offer or use the Specialist Services, we may collect, use, and store the personal data described below. We also disclose certain information to third parties, as described further below. The information we collect is received directly or indirectly from you and generated in the course of your use of the Site. The data we collect is not used for marketing or any other purposes except as specified in this Privacy Policy.
Identity Data includes name, nickname, age, gender, nationality, marital status, language, education and job history in case of the Specialist
Contact Data includes country of residence, address, email address and telephone numbers
Financial Data includes bank account and payment card details
Transaction Data includes details of services you have purchased from us
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and Site, and other technology on the devices you use to access the Site.
Account Registration Data includes certain information in connection with the account registration process such as whether you registered using any Third Party Services and whether you verified your email address or phone number.
Usage Data includes information about how you use our Site and the Specialist Services.
Login Data: includes information regarding logins and activity conducted during that log in such as when you log in, the number of messages received or sent through the Site during that log in, and whether you have been assigned, started or completed a counseling goal. This does not include the content of any messages sent or received by you or the content of any counseling goals.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Specialists and users may connect their Hakkini calendar with their outlook/google calendar or any other calendar they use. Our calendar integration only checks the duration and free/busy status of the events in your calendar so that we don’t book you when you’re busy. We never store who you are meeting with, their email address, the meeting title, or any other details about the appointments in your connected calendar.
We also get information about you and your activity outside the Site from our affiliates, advertisers, partners and other third parties we work with. For example, online advertisers or third parties share information with us to measure, report on or improve the performance of ads, or to figure out what kinds of ads to show you.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Data Privacy Policy.
We collect information about your health the extent you share such information with us.
How We Collect Your Personal Data
We collect personal data through one or more of the following ways:
when you visit the Site we collect data regarding the particular pages you have visited or viewed, the amount of time you spent on the Site, the Site errors you experienced, your mobile device ID and IP address.
when you register your account we collect Identity Data, Contact Data and Profile Data
when any content you post in the Booking page would contain any personal data
when you have a session with the Specialist, we collect general data regarding your counselling sessions such as whether a live session has been scheduled, whether a Specialist or user joins a scheduled session, when a counseling session began and ended and whether a counseling session was canceled or re-scheduled.
referring websites or third parties, including social media sites
when you elect to receive marketing communications from us
the maintenance and analysis of Website server logs; and
“cookies” (small text files placed by us on your computer(s)), single pixel GIF image files, Website server log analysis and other similar technological means.
How We Use your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To communicate with you (to contact you or provide you with information, alerts and suggestions that are related to the Site; to verify your identity |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To create your Specialist/User account on our Site, to let you log in to your account and use the Site; to manage your account, provide you with customer support and ensure you are receiving quality service |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To manage your Specialist bookings; to match you with a Specialist and facilitate the Specialist Services |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our Terms and Conditions or Data Privacy Policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services) |
|
To review content in the Booking form to detect activity that poses a risk to the safety of you, the Specialist and/or members of the public. |
(a) Identity (b) Contact |
Necessary for our legitimate interests |
|
To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation) (b) Necessary to comply with a legal obligation |
|
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our services, marketing, customer relationships and experiences |
(a) Identity (b) Usage |
Necessary for our legitimate interests (to define types of customers for our services, to keep the Site updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our services and grow our business) |
“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
“Performance of Contract” means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
How We Make Sure Your Personal Data Is Secured
To protect your personal data, we take reasonable precautions to try to ensure that it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
We implement and maintain appropriate technical, security and organisational measures in relation to the processing of your personal data so that the processing will meet the requirements of applicable Data Protection Laws and ensure the protection of your rights.
We use Zoom for healthcare to enable face-to-face meetings between Users and Specialists. Any data in motion is encrypted at the application layer using Advanced Encryption Standard. For more information please click the following links: https://zoom.us/healthcare and https://support.zoom.us/hc/en-us/articles/207652183
Storage of payment details and processing of payments is managed through Stripe, a third party payment services provider. You must agree to the Stripe terms of service to make purchases. We assume no responsibility or liability for the privacy practices or any other actions of Stripe. You can find more information on the privacy practices of Stripe here: https://stripe.com/us/privacy
Retaining Personal Data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Your Rights
Under certain circumstances, you have rights under applicable Data Protection Laws in relation to your personal data:
Right to request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data information
Right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact us via this e-mail address: [email protected]
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
Whilst we will always work with you to resolve any concerns you have about the use of your personal information, under GDPR you have the right to lodge a complaint with the supervisory authority in your country of residence if you have any concerns about our use of your personal information.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the period for which we hold it.
Protecting your fellow User
We respect other people's rights, and expect you to do the same. You will not post content or take any action on the Site that infringes or violates someone else's rights, privacy or otherwise violates the law. We can remove any content or information you post on the Site if we believe that it violates this Data Privacy Policy or the Terms of Use. You will not use our copyrights or any confusingly similar marks, without our written permission. If you collect information from Users, you will: obtain their consent, make it clear you (and not us) are the one collecting their information, and post a privacy policy explaining what information you collect and how you will use it. You will not post anyone's identification documents or sensitive financial information on the Site. You will not tag fellow Users or send email invitations to non-users without their consent.
Sharing of Personal Data With Third Parties
Your personal data may be disclosed to third parties for one or more of the following purposes:
For business purposes and advertising: We may share a User's information with a Specialist and a Specialist's information with a User only as necessary for facilitating the Specialist Services. We may also share your information with vendors and service providers, including our data hosting and data storage partners, analytics and advertising providers, and vendors providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms.
We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Data Privacy Policy.
We require all third parties to respect the security of personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We will not otherwise share personal information with any third party except where we are permitted to under data protection laws or required to by law.
You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of our marketing email communications.
International Transfers
The Site is controlled and operated by us from the United Arab Emirates. By accepting the terms of this Privacy Policy you agree that any personal information you provide to us through use of the Site may be stored and processed, transferred between and accessed from the United Arab Emirates and other countries that may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Policy at all times.
Privacy Disputes
You will resolve any claim, cause of action or dispute (claim) you have with us arising out of or relating to this Data Privacy Policy exclusively in the DIFC Courts. The laws of England and Wales will govern this Data Privacy Policy, as well as any claim that might arise between you and us, without regard to conflict of law provisions.
If anyone brings a claim against us related to your actions, content or information on our Site, you will indemnify and hold us harmless from and against all damages, losses, and expenses of any kind (including reasonable legal fees and costs) related to such claim.
Cookies and Other Web Technologies
The types of cookies and similar technologies used by us and our partners in connection with the Site can be classified into one of five categories, namely ‘essential website cookies‘, ‘functionality cookies‘, ‘analytics and performance cookies‘, ‘advertising cookies‘, and ‘social media cookies‘. Cookies do a lot of different tasks to ensure you enjoy your visit to our Site, for example, they are used to remember your preferences on our Site, to help you navigate between pages more efficiently, to enable you to log into your account more easily and to make sure the adverts you see on our Site are relevant to you and your interests. We have set out some further information about each category, and the purposes of the cookies we and third parties set in the following table.
You can block these cookies and similar technologies by changing your browser setting. However, in relation to those that are essential for the operation or improve the functionality of the Site, this may impact your use of the Site.
|
Type of cookie |
What it does |
|
Cookies necessary for essential website purposes |
These cookies are essential to provide you with the Site and any services available through theSite and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like transactional pages and secure login accounts, would not be possible. |
|
Functionality Cookies |
Functionality cookies record information about choices you’ve made and allow us to tailor the Website you. These cookies mean that when you continue to use or come back to the Site, we can provide you with our services as you have asked for them to be provided. These cookies allow us to:
|
|
Performance Cookies |
We use performance/analytics cookies to analyze how the Site is accessed, used, or is performing in order to provide you with a better user experience and to maintain, operate and continually improve the Site. We use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Site. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Site. The reports disclose Site trends without identifying individual visitors. For more information on Google Analytics, see here. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout. These cookies allow us to:
|
|
Social Media Cookies |
On some pages of our Site, third parties that provide applications through our Site will set their own cookies in order to track the success of their applications or customize applications for you. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us. |
You can choose to enable or disable cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser.
You can choose to delete cookies at any time; however you may lose any information that enables you to access the Site more quickly and efficiently including, but not limited to, personalisation settings.
It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
Final Words from Hakkini
We try to keep Hakkini safe, but you use it at your own risk. We are providing the Site “As Is“ without any express or implied warranties. We do not guarantee that Hakkini will be safe or secure. We are not responsible for the actions, content, information, or data of third parties, and you release us, our directors, officers, employees, and agents from any claims and damages, known and unknown, arising out of or in any way connected with any claim you have against any such third parties.
Please understand, that we treat your use of our platform with the utmost respect to your privacy. We want you to feel confident using our services. We keep all information not disclosed above private between the Specialist and the User, keeping only non-decimated “file“ copies for reference in case of legal dispute or court order. File retention protects both the User and the Specialist’s safety. We are not responsible for data lost/exposed/used due to the nature of the Internet and digital environments, including illegal actions of hackers and criminals, technical malfunctions of servers and database etc. These are the accepted risks of our Users and users of the Internet in general. You are agreeing to this standard in using our site.
If you have any questions pertaining to this Data Privacy Policy and its contents, please direct your correspondence to us [email protected].
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