Emirates Telecommunications Group Company P.J.S.C (“Etisalat”), respects the privacy of all personal information and data provided by users of our GoChat mobile application (“Platform”). This Privacy Policy (“Privacy Policy”) explains how we collect, process, use, disclose and transfer your personal information and applies to the personal data that you provide us directly, or which we may obtain from other sources.

By using our services or interacting with our Platform, you agree and consent to the collection, use and transfer of your information as set out in this Privacy Policy.

Emirates Telecommunications Group Company P.J.S.C (“Etisalat”) is the data controller of your Personal Data. We decide how and why your personal data is processed, either alone or jointly with others, through your use of the Platform.

It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or Processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data.

This Privacy Policy uses a number of definitions, which are set out below:

Data Protection Officer (DPO): means any natural or legal person appointed by the Controller or Processor to undertake the responsibilities of ascertaining the compliance of his/her entity with the controls, conditions, procedures and rules for Processing and protecting Personal Data stipulated herein, and ascertaining the integrity of its systems and procedures in order to ensure compliance with the provisions hereof.

Personal Data: means any information of any form related to an identifiable individual, or an identified natural person, or one who can be identified directly or indirectly by way of linking data, using identifiers such as name, voice, picture, identification number, online identifier, geographic location, or one or more special features that express the physical, psychological, economic, cultural or social identity of such person. It also includes Sensitive Personal Data and Biometric Data.

Process and Processing: means any operation or set of operations, which is performed on Personal Data using any electronic means, including Processing and other means. This process includes collection, storage, recording, organization, adaptation, alteration, circulation, modification, retrieval, exchange, sharing, use, or classification or disclosure of Personal Data by transmission, dissemination or distribution, or otherwise making it available, or aligning, combining, restricting, blocking, erasing or destroying Personal Data or creating models therefor.

We process different categories of personal data to enable us to provide services to you, which we have grouped together below:

• Contact Data: Includes but is not limited to address, email address and telephone number.
• Identification data: Includes but is not limited to your name, title, date of birth, age, gender, country of residence and photo.
• Profile Data: includes your username and profile, your service preferences and any reviews you may have submitted;
• Web Data: Includes but is not limited to cookies, user activity logs, IP address and Platform visitor interaction data.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and third parties (i.e., any external partners) and your preferences when receiving communications.
• Device contacts book: to enable you to communicate with friends, we may, with your permission, collect information from your device’s contacts’ book.
• Camera and Photos: some of our services require us to collect images and other information from your device’s camera and photos, including where you share these with friends.
• Location: We collect information about your approximate location, including location information based on your SIM card and/or IP address. With your permission, we may also collect precise location data (such as GPS).

We will use the information we collect about you in the following ways:

• register you as a user and communicating with you about your account, provide our services, to share information about our products, services, and promotional offers that we think may interest you, or entering into a contract with you;
• send you notifications about changes to our services and updates to the Platform, this Privacy Policy or our terms and conditions;
• provide you with user support;
• enable you to share User Content and interact with other users;
• administer and improv the Platform, improving our products and services
• monitor and analyze trends and usage.
• enhance the safety and security of our products and services.
• enforce our Terms of Use or other policies, or comply with a legal or regulatory obligation that we have;
• where we have your consent to using your Personal Data for a particular purpose, for example to deliver relevant content to you, including promotional offers, and to make suggestions and recommendations about services that may be of interest to you. 

We will only Process your Personal Data where we have an appropriate legal basis to do so. Appropriate legal basis includes:

Performance of a Contract: in order to perform a contract with you or to take steps at your request before entering into such a contract, or to terminate a contract;

Comply with legal obligation: in order for us to comply with any legal or regulatory obligation to which we are subject;

Protection of your vital interests: in order to protect your vital interests; and

Consent: in certain circumstances, we may ask for your express consent to collect, process or transfer your Personal Data, for example in relation to opting into receiving direct marketing. You have the right to withdraw your consent at any time simply by contacting us.

We will get your express opt-in consent before we use or share your Personal Data with any third party for marketing purposes. Where we share your Personal Data with a third party in connection with a service, please check their terms and conditions and privacy policy relating to their privacy practices.

Where necessary to fulfil the purposes described in this Privacy Policy, we may disclose your Personal Data to certain third-parties, vendors and service providers or affiliated employees, contractors and entities as described below.

• Our service providers, contractors, and agents: where these perform services on our behalf, like email and hosting services, and customer services and support.
• Analytics services: to provide analytics services in order to communicate with you more effectively and in a customized manner.
• For advertising: to offer you targeted ad delivery to personalize your user experience, and to undertake web analytics. Advertisers may also share with us the data they collect about you.
• For security and compliance with legal requirements: to comply with applicable law, where reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements.
• With our affiliates: within our group of companies that are related by common ownership or control to enable or support us in providing our services.
• With our professional advisers: such as lawyers, bankers, auditors and insurers.
• With regulators and other authorities.
• With your consent: where you agree that we may share data to third parties outside the scope of this Privacy Policy.
• By submitting your Personal Data, you agree to this Processing by such third parties and for the purposes set out in this Privacy Policy. 

We have implemented appropriate security measures to prevent accidental loss of or unauthorized access to, use, amendment or disclosure of your Personal Data. We also limit access to your Personal data to those employees, agents, contractors and other third parties who have a business need to know, are subject to a duty of confidentiality and who will process your Personal Data strictly on our instructions.  

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes for which we collected it and/or for the purpose of satisfying any legal or reporting requirements.  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. 

We may collect your personal information from, transfer it to, and store and process it in the United Arab Emirates and other countries outside of where you live. Whenever we share information outside of where you live, when we are legally required to do so, we make sure an adequate transfer mechanism is in place. We also make sure any third parties we share information with have an adequate transfer mechanism in place, as well. If you are accessing the Platform from outside the United Arab Emirates, you consent to the transfer, storage, and processing of your data in and to the United Arab Emirates or other countries.

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. These include:

Withdraw consent – You have the right to withdraw your consent to processing your Personal Data at any time, however, if you do, we may not be able to provide services to you or you may not be able to access features of the Platform. Withdrawing consent will not affect the lawfulness of any Processing carried out prior to your withdrawing your consent.

We may require specific information from you to help us confirm your identity and ensure your rights to access your Personal Data. This is a security measure to ensure that your Personal Data is not disclosed to someone who has no right to receive it.

If you wish to exercise any of the rights set out above, please contact [support@gochatapp.net].

The Platform may, from time to time, contain third-party data, information, applications, features or materials from third parties (“Third-Party Materials”).  Through these Third-Party Materials you may be providing information to such third parties as well as Etisalat.  Etisalat is in no way responsible for any Personal Data that may be collected through those websites. Etisalat encourages you to review the privacy notices of those third parties you interact with through our services.

We may use cookies and/or tracking technologies to distinguish you from other users of the Platform or to remember your preferences. This allows us to enhance your experience when browsing the Platform, and also improve the Platform. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

GoChat is not directed at children under the age of Sixteen (16) and Etisalat does not knowingly collect Personal Data from persons who are under the age of Sixteen (16) years old without the consent of a parent or legal guardian. Persons under age Sixteen (16) may only use our Platform with the involvement and consent of a parent or legal guardian.

15.1 Users in California

California residents have certain privacy rights as specified under California law, including the California Consumer Privacy Act of 2018 (“CCPA”). Our privacy principles and the privacy controls we offer to all users, set out in our Privacy Policy, are in line with these laws. This Notice makes sure we cover the California-specific requirements. If you are an eligible California user, your privacy rights include:

Right to Know — You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of the Personal Data we hold about you.

Right to Correction — You have the right to have inaccurate personal information about you corrected.

Right to Deletion — You have the right to request deletion of Personal Data that we have collected about you.

Right to Non-Discrimination — If you choose to exercise any of your rights under the CCPA, we will treat you like all other users. In other words, there is no penalty for exercising your rights under the CCPA.

Right to Opt-Out - You have the right to opt out of the sale of your personal information.

The CCPA has a specific definition of a “sale”. Whilst Etisalat does not, in the traditional sense, sell your personal information or the personal information of any of our users, we may use cookies that make non-personally identifiable information available to certain third parties.

To find out more information about the Personal Data we collect about you, please see the sections above entitled “Data We Collect from You and How We Use It”.

To learn about the business and commercial purposes for which we collect your Personal Data and the categories of service providers who have access to your Personal Data, please see the sections above entitled “How We Use Your Data” and “Disclosure of Your Personal Data.”

 

 

 

15.2 Users in the EEA and the UK

Users in the EEA and UK have certain privacy rights as specified under EU and UK law, including the General Data Protection Regulations (GDPR) and UK Data Protection Act 2018. Our privacy principles and the privacy controls we offer to all users, set out in our Privacy Policy, are in line with these laws. This notice makes sure we cover the EEA and UK specific requirements.

a. The Purposes and Legal Basis for Processing

Our Privacy Notice explains the reasons why we process your Personal Data. We only process Personal Data when we have a legal basis for the processing, as follows:

Contract: To fulfil a contract with you, when you’ve entered into an agreement with us;

Consent: in certain circumstances, we may ask for your consent, including to provide you with marketing communications, provided you have not objected or opted-out, as may be appropriate under applicable law;

Legal Obligation: To comply with any legal obligation applicable to us around the world;

Legitimate Interest: we may also process your Personal Data for the purposes of our own legitimate interests or for the legitimate interests of others, provided that, processing does not and shall not outweigh your rights and freedoms.

b.  Automated Decision-Making and Profiling

We may use profiling and analytics for product development purposes and business intelligence purposes. These analytics help us understand and improve our products and better serve our clients and consumers.

c. International Transfers

Your Personal Information may be transferred to, stored at, or processed in the United Arab Emirates and other countries that may not have equivalent privacy or data protection laws.

We use specific standard clauses to facilitate transfers of personal data from the EEA to third countries and have agreements in place with third parties to restrict and regulate their processing of your data. By submitting your data, accessing our site, or using our services, you consent to this transfer, storage, and processing by Etisalat and its processors.

We generally use approved Standard Contractual Clauses to assure that Personal Data is adequately protected when it is transferred out of the EEA, the UK, or Switzerland to countries without an adequate level of data protection, but we may also make transfers to recipients with approved binding corporate rules or appropriate data processing agreements.

This describes privacy of information collected and/or generated during the use of the GoChat GPT feature on GoChat Messenger (the “Feature”):

1. Information we may collect:

• User Content:

By utilizing the Feature, you acknowledge and agree that Third Parties or Azure OpenAI Service may collect information from the content you provide, including input, file uploads, and feedback. Such collection of information is subject to the respective third party’s or Azure OpenAI Services own policies and terms, and you are solely responsible for any data provided by you through the Feature.   

 

2. Usage Information:

We may receive automatically from use of the Feature the following message:

“When you visit, use and interact with the Service, we may receive the following information about your visit, use and interactions (“Technical Information”):

• Log Data: Information that the Feature may automatically sends whenever you use (“log data”). Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Feature.
• Usage Data: We may automatically collect information about your use of the Feature, such as the content that you view or engage with the actions you take, as well as your times zone, country, the dates and times of access, type of mobile device, IP address.
• Device Information: Includes name of the device, operating system that you are using. Information collected may depend on the type of the device you use and its settings.
• Analytics: we may use a variety of online analytics products to help us analyse how users use Feature and enhance your experience.

 

3. How we may use the collected information
   • To provide, administer, maintain and/or analyse the Feature.
   • To communicate with you;
   • To comply with legal obligations and legal process, and to protect our rights, privacy, safety or property and/or that of our affiliates, you or other

If you have any questions, concerns or complaints regarding our compliance with this Privacy Policy and the data protection law, or if you wish to exercise your rights, please contact us at support@gochatapp.net . We will make reasonable efforts to respond to your questions or concerns and to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by the data protection law.  

This Privacy Policy and any dispute or claim arising out of, or relating thereto, its subject matter or formation (including non-contractual disputes or claims) shall be governed by, and construed in accordance with, the laws in force in the Emirate of Abu Dhabi of the United Arab Emirates and the courts of Abu Dhabi in the United Arab Emirates shall have exclusive jurisdiction to settle any such dispute or claim. 

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will seek to inform you by notice on our Platform and by providing any other notice required by law. Your continued use of the Platform following an amendment or notice of change constitutes your acceptance of the updated policy.