Our contact details are as follows:
You have the right to make a complaint at any time to the competent supervisory authority.
It is important that the personal data we hold about you is accurate and current. Please keep us informed on any changes to your personal data during our relationship with you.
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies, or for any personal data that may be collected through these websites or services, such as your contact or location information.
Please review the policies of these other websites before you submit any personal data to them or use their services.
We may collect, use, store and transfer different kinds of personal data about you as follows:
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offences.
We will collect and process the following data about you:
Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about yourself by filling in forms on the Site, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Site, subscribe to any of our Services, site share data via social media functions, enter a competition, promotion or survey, and when you report a problem with the Site or any of our Services. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you visit our Site we will automatically collect personal data including Device, Content and Usage Data.We collect this data using cookies and other similar technologies.
Location Data. We also use GPS technology and other location technologies to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use this particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in yourDevice’s settings.
Information we receive from other sources including third parties and publicly available sources.We will receive personal data about you from various third parties and public sources as set out below:
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
Please see Glossary: Lawful Basis below to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if w e ave your consent. You have the right to withdraw that consent at any time by contacting us.
Purpose / Activity
Type of data
Lawful basis for processing
To register you as a new Site user
To process in-Site purchases and deliver Services including managing payments and collecting payments
To manage our relationship with you including notifying you of changes to the Site or any Services
To enable you to participate in a prize draw, competition or complete a survey
To administer and protect our business and this Site including troubleshooting, data analysis and system testing
Necessary for our legitimate interests (for running our business, provision of administration and IT services, and network security)
When you consent to providing us with your personal data, we will also ask you to provide your consent to share your personal data with the third parties set out below for the purposes set out in the above data.
Whenever we transfer your personal data out of Jordan, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
You agree to indemnify and hold us and our affiliates, officers, directors, employees, agents, suppliers or licensors harmless from and against any liabilities, losses, damages or costs, including reasonable attorneys' fees, incurred in connection with or arising from any third-party claims, allegations, disputes, actions or demands asserted against any of them as a result of or relating to your content, data, your use of our Site or services or any wilful misconduct on your part.
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using [Secured Sockets Layer technology OR ALTERNATIVE ENCRYPTION TECHNOLOGY]. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way.
We will collect and store personal data on your Device using [application data caches and browser web storage (including HTML5)].
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
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 of 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 unauthorized 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.
In some circumstances, you can ask us to delete your data, see the Your legal rights section below for further information.
In some circumstances, we will 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.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data:
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 we hold about you and to check that we are lawfully processing it.
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.
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.
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.
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:
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.
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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at [email@example.com].
Glossary: Lawful Basis
“Consent” means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 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.
“Comply” with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal third partiess
Other companies in the Finto group acting as joint controllers or processors, providing IT and system administration services and undertaking leadership reporting.
External third parties
Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Regulators and other authorities
Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
Contact Data: billing address, delivery address, email address and telephone numbers.
Financial Data: bank account and payment card details.
Transaction Data: includes details about payments to and from you and details of in-Site purchases.
Device Data: includes the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
Content Data: includes information stored on your Device, including login information, digital content.
Profile Data: includes your username and password, in-Site purchase history, your interests, preferences, feedback and survey responses.
Usage Data: includes details of your use of any of our applications or your visits to any of our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Location Data: includes your current location disclosed by GPS technology or other location technologies.