WHAT DOES THIS PRIVACY POLICY COVER?
Your privacy is extremely important to Hatla2ee. We are committed to protecting your Personal Data (as that term is defined further below). We want to be transparent with you about how we collect and use your Personal Data in making our website and mobile applications (“Platform”) available to you and tell you about your privacy rights and how the law protects you.
This Privacy Policy aims to give you information on how Hatla2ee collects and processes your Personal Data through your use of this Platform. We will ensure that all processing of your Personal Data is conducted in accordance with applicable data protection laws.
By providing your Personal Data through our Platform, you explicitly agree to the collection, use and processing of your Personal Data as described in this Privacy Policy. You acknowledge that you have read and understood this Privacy Policy and agree to the terms outlined herein.
If you do not agree to our processing of your Personal Data, please do not provide your information or use our Platform.
With that in mind, this Privacy Policy covers the following:
We may revise this Privacy Policy from time to time, with or without notice to you. If that happens, the new version of this Privacy Policy will be made available on this page.
WHO WE ARE AND HOW TO CONTACT US
Who we are
Hatla2ee Egypt L.L.C operates the Platform and is therefore the controller of your Personal Data (referred to as either “Hatla2ee”, “we”, “us” or “our” in this Privacy Policy).
How to contact us
You can contact us by emailing: info@hatla2ee.com.
PERSONAL DATA WE COLLECT FROM YOU
The Personal Data we collect directly from you is outlined in the table below.
“Personal Data” is information about an individual from which that individual is either directly identified or can be identified. It does not include ‘anonymised data’ (which is information where the identity of an individual has been permanently removed). However, it does include ‘pseudonymised data’ (which is information which alone doesn’t identify an individual but, when combined with additional information, could be used to identify an individual).
|
Category of Personal Data |
What this means |
|
Identity Data |
First name, last name, username or similar identifier, and profile photo. |
|
Contact Data |
Email address, telephone number(s). |
|
Location Data |
Approximate location if you enable this feature via your device. |
|
Listings Data |
Details about your previous and current listings on the Platform, as well as details of other users’ listings that you have viewed, and offers you have made for other users’ listings. |
|
Marketing Data |
Your preferences in receiving marketing messages from us. |
|
Chat Data |
Details of messages that you exchange with other users of the Platform through the ‘Chat’ feature, including any additional Personal Data you may disclose in such messages. |
|
Call Data |
Recordings of calls between you and our teams, which are recorded for monitoring and training purposes. |
|
Behavioural Data |
Inferred or assumed information relating to your behaviour and interests based on your activity on the Platform. This is most often collated and grouped into ‘segments’ on an aggregated basis. |
|
Technical Data |
Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Platform or use our services. |
Aggregated data
We also collect, use and share ‘aggregated data’, such as statistical or demographic data for a number of purposes. Aggregated data may be derived from your Personal Data, but once in aggregated form it will no longer constitute Personal Data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Behavioural Data to calculate the percentage of users accessing a specific Platform 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 Privacy Policy.
Special categories of personal data
We do not knowingly collect any ‘special categories of personal data’ about you (this includes, for example, details about your race or ethnicity, religious or philosophical beliefs, political opinions, information about your health, genetic and/or biometric data, and information about criminal offences and convictions).
We advise you not to share any of that data with us (for example, through our support chat function) or other users of the Platform (for example, through the user-to-user chat function). However, should you choose to share such data with us or other users of the Platform, you consent to us processing such data in accordance with this Privacy Policy.
What happens if you refuse to provide necessary Personal Data?
You do not have to provide any Personal Data to us. However, where we need to process your Personal Data either to grant you access to the Platform or to comply with applicable law, and you fail to provide that Personal Data when requested, we may not be able to provide you access to the Platform. For example, we need your email address in order to register your account on the Platform.
PERSONAL DATA WE COLLECT FROM OTHER SOURCES
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are set out in the table below.
|
Third party source |
Categories of Personal Data |
|
Our affiliates |
|
|
Analytics providers |
|
|
Advertisers |
|
HOW WE USE YOUR PERSONAL DATA AND WHY
We will only use your Personal Data for the purposes for which we collected it as listed below, 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 update this Privacy Policy and we will explain the legal basis which allows us to do so (please refer to the ‘Changes to this Privacy Policy’ section further below).
What is our ‘legal basis’ for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, applicable privacy laws require us to ensure that we have a ‘legal basis’ for that use. Most commonly, we will rely on one of the following legal bases:
We have set out below, in a table format, the legal bases we rely on when processing your Personal Data.
|
Purpose |
Categories of Personal Data |
Why we do this |
Our legal basis |
|
Account creation |
|
To register you as a user on the Platform and manage your user account. |
Contractual Necessity |
|
Operation of our services |
|
To operate the Platform and enable your use of the Platform, including by allowing you to interact with other users of the Platform. |
Contractual Necessity |
|
Analytics |
|
To understand how you and other users use the Platform and to segment our userbase into groups for marketing and research purposes. |
Contractual Necessity |
|
Marketing |
|
To send commercial and promotional communications on products and services provided by us through the Platform using different means (such as email, text message, push notification or telephone call), where you have agreed to this. |
Consent |
|
Troubleshooting |
|
To track issues that might be occurring on our Platform and to address them. |
Contractual Necessity |
|
Fraud prevention |
|
To keep our Platform and associated systems operational and secure. |
Compliance with Law
|
WHO WE SHARE YOUR PERSONAL DATA WITH
The table below describes who we may share your Personal Data with and why we share it.
We require all recipients of your Personal Data to implement appropriate security measures to adequately protect it, consistent with our policies and any data security obligations applicable to us. We do not permit our third-party service providers who process your Personal Data on our behalf to use it for their own purposes, and only permit them to process your Personal Data for specified purposes in accordance with our instructions.
|
Recipients |
Why we share it |
|
Other users of the Platform |
We need to share some of your Personal Data with other users of the Platform when you wish to transact with them through the Platform. By placing a listing on our Platform, that information and any Personal Data associated with your account profile (including your username) will be publicly accessible to, and may be copied and shared externally by, all other users of our Platform. Such information may also appear in third party search engine results (for example, Google search results). Please ensure that you are comfortable with such information being publicly available before submitting it on our Platform. |
|
Service providers |
Our service providers provide us with a range of services which are necessary for the operation of the Platform (for example, IT, system administration services, or marketing services), and may have access to your Personal Data as a result. |
|
Affiliates |
Hatla2ee is part of the Dubizzle Group, which operates other consumer platforms and share technology with Hatla2ee. Our affiliated companies may require access to your Personal Data as they help us operate the Platform and manage user data. We may also use your Personal Data to understand how you use various products operated by the Dubizzle Group as a whole. |
|
Professional advisers |
Our lawyers, bankers, auditors, insurers and other advisers may require limited access to your Personal Data when they provide consultancy, banking, legal, insurance and accounting services to us. |
|
Public authorities |
Public authorities may require us to disclose user data to them under certain circumstances, where required by law (for example, in the event of a police investigation). |
|
Acquirer(s) |
We may share your Personal Data with third parties in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, so that any potential acquirer(s) may continue operating the Platform. Where that is the case, we will ensure that any such recipient(s) continue to use your Personal Data in accordance with this Privacy Policy. |
Data transfers
We may transfer your Personal Data to jurisdictions outside of Egypt that may not provide the same level of data protection as is available in your home country. Such transfers will only occur when necessary for the purposes set out in this Privacy Policy. In all cases, we will ensure that any cross-border transfers of your Personal Data comply with the requirements set forth in applicable data protection laws, including implementing appropriate safeguards to protect your data.
HOW WE KEEP YOUR PERSONAL DATA SECURE
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost or altered or used or accessed in an unauthorised way.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such persons are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to mitigate any impact to your privacy and to work with relevant regulators.
In order to help maintain the security of your information, you should protect the confidentiality of your username and password.
HOW LONG WE STORE YOUR PERSONAL DATA
We will only retain your Personal Data for as long as we reasonably need to use it for the purposes set out in this Privacy Policy, unless a longer retention period is required by applicable law (for example, for regulatory purposes).
Under some circumstances, we may anonymise your Personal Data so that it can no longer be associated with you. We may retain such anonymised data indefinitely.
Our data retention policies are reviewed at regular intervals and comply with all applicable requirements.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
Your rights
Under some circumstances, you may have certain rights in relation to your Personal Data. For example, you may have the right to:
Please note that not all of the rights listed above may be available to you, and some rights may only be exercisable in specific circumstances.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us.
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 your 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 of receipt. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.
Although we will typically not charge a fee for exercising your rights described above, we reserve the right to charge a reasonable fee in some circumstances (for example, if your request is unreasonable or if you submit an excessive number of requests).
Complaints
If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us. We will reply to your complaint as soon as we can.
If you are unsatisfied with our response to any issue that you raise with us, you may have the right to submit a complaint to the data protection authority in your jurisdiction.
MARKETING COMMUNICATIONS
OUR POLICY ON MINORS
This Platform is not intended to be used by minors, and we do not actively monitor the age of our users.
We request that minors do not provide personally identifiable information through the Platform. By consenting to this Privacy Policy, you acknowledge and warrant that you are of at least 18 years of age and that you have the full legal capacity to agree to this Privacy Policy. If you are under the age of 18, please obtain your parent's or guardian's permission before you provide any Personal Data to us.
If you become aware that a minor has been using the Platform in breach of this restriction, please contact us if you would like us to remove their Personal Data from our systems.
THIRD PARTY LINKS
This Platform may include links to third party websites and applications. Clicking on those links will take you off-Platform and may allow third parties to collect or share your Personal Data. We do not control these third-party websites and applications and are not responsible for their privacy practices. When you leave our Platform, we encourage you to read the privacy policy of every website and application you visit.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to update this Privacy Policy at any time, with or without notice to you.
Where that is the case, we will update this page to display the revised Privacy Policy and may also under certain circumstances notify you (for example, by email).
Any revisions to this Privacy Policy will be effective immediately once posted on this page.We encourage you to check this page regularly since your continued use of the Platform following any changes to this Privacy Policy will be deemed to constitute your acceptance of such change.
