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Privacy Policy

Introduction to Privacy Policy

Please read this Privacy Policy carefully before using the “Website” and mobile applications (“App”). This Website and App are owned, registered and operated by “Platform Owner” (“we”, “us” “our”). This Platform serves as a conduit for the Platform Owner’s services to be delivered directly to Platform Users via an app or a website. The “Platform” refers to the combination of this App and the Website. The Platform Users of the Website or App, hereinafter referred to as “User” or “you” or “your” or “yourself,” “registered user” or “guest user,” signal their willingness to be governed by these Terms & Conditions by using this Platform (“Agreement”). If any information is acquired through this Platform, it will be secured, safeguarded, and used to provide you with better and more appropriate services, as well as for authorized purposes.

Our privacy policies are subject to change without notice at any time. Though every attempt will be made to keep you aware of any changes to the policy, you are urged to examine it on a regular basis.

By using our website application or downloading our mobile app you agree to be bound by the terms and conditions of this Privacy Policy. Because this policy allows us to offer you with a safe and enjoyable experience, we will be unable to register you if you do not agree to these terms.

You fully consent to our use and dissemination of your personal information in accordance with this Privacy Policy by simply using the Platform. This Privacy Policy is part of and subject to the Terms of Service.

Scope and Definition

This policy shall regulate the Platform Owner’s collection of data, use of data, and handling (“usage”) of Personal Information (“PI”) and Sensitive Personal Data or Information (“SPDI”) in line with the Rules.

“Personal Information” refers to any information that, alone or in combination with other personal or identifying information, can be used to identify, find, or contact an individual. Platform Owner collects the following Personally Identifying Information (“PII”) in a form from Users during their usage of the Platform or the VTS Device for this purpose:

  • Name of the User
  • E-mail Address
  • Credit card or debit card information
  • necessary for payment (excluding passwords, PIN codes, and expiration dates) (CVVs etc.)
  • Billing and transaction information
  • Any other information that We deem necessary for the User’s usage of the Platform or the VTS device.

“Sensitive Personal Information” refers to personal information that includes information about:

You hereby represent to Platform Owner that:

the information you give to Platform Owner from time to time is and will be authentic, correct, current, and up to date, and that you have all of the necessary rights, permissions, and consents to transmit such information to Platform Owner.

The provision of the Information to Platform Owner, as well as the Platform Owner’s subsequent storage, collection, usage, transfer, access, or processing of the same, shall not violate any third-party agreement, laws, charter documents, judgments, orders, or decrees.

Your information will be mostly stored electronically, but certain data may also be saved physically. We may keep, collect, process, and use your data outside of Iraq in accordance with relevant laws. We may enter into contracts with third parties (both inside and outside of Iraq) to store or process your information or data. These third parties may have their own security requirements to protect your information or data, and we will require such third parties to implement acceptable security measures to protect your information or data on a commercially reasonable basis.

Platform Owner collects, uses, stores, and processes your Information for any purpose permissible under applicable laws (including where the applicable law provides for such collection, usage, storage, or processes in accordance with the user’s consent) connected with a function or activity of each of Platform Owner’s entities, which shall include the following:

  • To ease your usage of the Platform or other services provided by Platform Owner’s organizations.
  • To answer to your enquiries or fulfill Your requests for information about the various products and services available on the Platform.
  • To send you information, materials, and offers from the Platform Owner, as well as to provide you with information about products and services accessible on the Platform.
  • To give you critical information about the Platform, such as updates to the terms and conditions, user agreements, and policies, as well as other administrative information.
  • To send you surveys and marketing materials that Platform Owner considers may be of interest to you.
  • To assist you with resolving any issues you may have encountered while using the Platform, including any technical issues.
  • For proper platform administration.
  • Internal platform reviews and data analysis (e.g., to determine the number of visitors to specific pages within the Platform).
  • To enhance the Platform’s services, content, and advertising.
  • To facilitate various programs and activities undertaken by Platform Owner or third-party service providers and business allies.
  • To undertake scholarly research and surveys.
  • To ensure the Platform’s integrity.
  • To respond to legal, judicial, or quasi-judicial proceedings and offer information to law enforcement agencies or in connection with a public safety investigation, as permitted by law.
  • To undertake analytical studies on numerous elements such as user behavior, user preferences, and so on.
  • To implement information security practices.
  • To identify any security breaches, computer contamination, or computer virus.
  • To investigate, prevent, or take action in the case of criminal actions and suspected fraud.
  • As part of an inquiry or internal audit, do forensics on the affected computer resource.

Personal Information Processing Legal Basis

We will normally collect Limited Personal Information from you only if it is required to perform a contract, including a minimum KYC requirement to on-board you, the processing is in Our legitimate interests and is not overridden by your data protection interests or fundamental rights and freedoms, or We have your consent. In some situations, we may be required by law to gather Personal Information from you. If We process Personal Information with your consent, you have the right to withdraw your consent at any time.

Personal Information Collection and Use

We process personal information in the United States and Iraq. If you are a resident of the European Economic Area, and your Personal Information is processed outside the EEA, we will ensure that the recipient of your Personal Information provides an adequate level of protection, for example, by entering into standard contractual clauses for the transfer of Personal Information approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or We will seek your prior consent to such international data transfers.

If this section and any other provision of this Privacy Policy conflict, the policy or component that is more protective of Personal Information will take precedence to the extent of the disagreement.


Cookies are little data files that are widely utilized as anonymous unique identifiers. These are sent to your browser by the websites you visit and are kept in the internal memory of your device.

The app may, however, use third-party code and libraries that use cookies to collect data and improve their services. You have the choice to accept or reject these cookies and to be notified when a cookie is sent to your device. If you opt to reject our cookies, you may be unable to utilize certain features of this Service.

Other than for internal Platform development and maintenance, the information collected via cookies is not sold, rented, or shared with any third parties.

Links to Additional Sites

It is stated that you may encounter links to third-party websites, ads, or electronic communication services. You will be taken to a third-party site if you click on a third-party link. It should be noted that Platform Owner does not operate these external sites. Any use of such third-party website or use of any service or product obtained through a third party is at your own risk, and Platform Owner is not liable for any loss / damage or otherwise. As a result, we strongly recommend that you read the Privacy Policies of these websites. We have no control over, and accept no responsibility for, any third-party website or services’ content, privacy policies, or practices.

Third-Party Disclosure

Platform Owner is free to reveal your information, in whole or in part, to third-party service providers who may help us perform services. These service providers are only allowed to access your data to complete the duties specified by the Platform Owner and are not permitted to disclose or use it for any other reason. Personal information may also be shared with third-party contractors, consultants, and other service providers who work for the Platform Owner and are contractually obligated to keep personal information confidential.

Data Security

Each Participant consents to the gathering and processing of personal data belonging to the Participant by participating or accepting any privileges offered under this policy. So that the Platform Owner and its Affiliates can fulfill their contractual responsibilities and exercise their rights.

We must always have a legal basis for using personal data under Data Protection Laws. This could be because the data is required for us to complete a contract with you, you have consented to our use of your personal data, or it is in our legitimate business interests to do so. We may use your personal data for marketing reasons with your (client’s) permission and were permitted by law, which may include contacting you via email, phone, or postal mail with information, news, and offers about our products and services. We will constantly try to completely protect your rights and to meet our obligations under data protection laws.

Dispute Resolution and Governing Law

In the event of a dispute, the Privacy Policy shall be controlled by and created in accordance with Iraqi law, without regard to conflict of laws principles. Any issues arising in regard to or under this Privacy Policy shall be resolved exclusively by Iraqi courts.


Platform Owner reserves the right, at its sole discretion, to add, revise, alter, change, or delete any portion of this Policy (in whole or in part). The most recent version of this Policy will be posted on the Platform from time to time. If the Act or the Rules change, or if any requirement arising under any applicable law, this Policy is deemed to be updated or modified to the extent necessary to comply with such amendment to the Act or the Rules, or to fulfill any requirement under the relevant laws.

Data Access

The user whose Personal Information and/or Sensitive Personal Data or Information is collected, received, possessed, processed, saved, transferred, dealt with, or managed by the Platform Owner may request about the type of data stored or processed by the Platform Owner. The individual will be given reasonable access to his or her Personal Information and Sensitive Personal Data or Information stored by the Platform Owner. If any data is incorrect or incomplete, a person may request that it be changed, modified, or updated.

Security Procedures

We have adopted industry standard security policies, rules, and technical measures to protect any type of personal sensitive information under our control from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction, or accidental loss.

Contact Us

If You have any complaints or concerns regarding the Platform or our services, or if You have any questions about this Privacy Statement, please contact us at yamme@daw-alfada.com