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1.Introduction
This Privacy Policy provides a comprehensive description of how Qashio collects, uses, and shares information about you as well as your rights and choices regarding such information. For purposes of this Privacy Policy, “Qashio”, “we”, “our”, and “us” refers to Qashio Software House Limited, and “you” or “your” refers to the natural person interacting with us.
This Privacy Policy applies to our mobile app, our emails and advertisements, and any other location, online or offline, operated by us that makes this Privacy Policy available to you (collectively, the “Service”).
As further described in the “Information Collected through the Product” section, when you apply for an account with Qashio as a business customer or create an account as an authorised user of a business customer (“Qashio Account”), access or interact with our online platform available at qashio.com through your Qashio Account (“Platform”), or use a physical or virtual payment card issued by a bank issuer managed through your Qashio Account (“Card”) (collectively, the “Product”), our processing of information through the Product is governed by the terms of our agreements with the issuing bank and the applicable business customer, including our Platform Agreement. In the event we are permitted to process the information for our own purposes, we will process the information in accordance with the practices described in this Privacy Policy.
Your use of the Service or Product constitutes your agreement to our data practices, and any other policies made available by us to you. If you do not agree, please notify us in writing, close your Qashio Account, delete any cookies you may have on your devices, and cease all use of the Service and Product. In certain circumstances, the business customer on whose behalf we provide services will need to confirm your choice before we can fully process your request.
If you have any questions or wish to exercise your rights and choices, please contact us at privacy@qashio.com or as further set out in the “Contact Us” section. If you are a data subject in Europe, please see the additional disclosures at the end of this Privacy Policy.
2.Information That Qashio Collects
2.1. Information Collected through the Service
We collect information when you use or interact with our Service. For example, we collect information when you browse our Website, read our emails, view our advertisements, engage in our affiliate referral program, apply for a job, contact sales, or ask us a question. We collect information that you actively provide to us, and information that is automatically collected through tracking technologies (described below).
The categories of information you provide to us through our Service include:
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
The categories of information we automatically collect through our Service include:
The types of tracking technologies we use to automatically collect information include:
You may limit our collection of this information through tracking technologies by changing your browser or device settings. However, doing so may affect or limit the features available to you. For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.
2.2 Information Collected through the Product
Our Product is designed for use by business customers and their employees and authorised users. Our processing of information collected through the Product or otherwise provided to us by a business customer in connection with their use of the Product is governed by the terms of our agreements with the issuing bank and the applicable business customer, including our Platform Agreement. In the event of a conflict between this Privacy Policy and the terms of any agreements between a business customer and Qashio, the terms of those agreements will control. In the event we are permitted to process the information for our own purposes, we will process the information in accordance with the practices described in this Privacy Policy. We are not responsible for how our business customers treat information we collect on their behalf, and we recommend you review their own privacy policies.
We collect information through the Product when you:
The categories of information you provide to us through the Product include:
Where you do not provide information when required—or where it is inaccurate, out-of-date, or unable to be validated—we may prohibit your use of the Product.
In addition, when you access or interact with our Platform, we automatically collect Service Use Data, Device Data, and Location Data through the types of tracking technologies listed in Section 2.A. above.
2.3 Information Collected from Other Sources
We also collect information from other sources. The categories of sources from which we collect information include:
We treat the information collected from other sources subject to any laws or contractual obligations applicable to us. In the event we are permitted to process the information for our own purposes, we will process the information in accordance with the practices described in this Privacy Policy.
3. How We Use Information
We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by law or contractual obligation applicable to us. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
4. Sharing Information
We share information we collect, including information that identifies you, in accordance with the practices described in this Privacy Policy. The categories of parties with whom we share information include:
Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by law or contractual obligation applicable to us. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
5. Other Parties
The Service and Product may link to or integrate with websites, platforms, and services operated or controlled by other parties. Some examples include:
Please note that when you interact with other parties, including when you leave our Service or Product, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the United Arab Emirates or elsewhere. We encourage you to familiarise yourself with and consult their privacy policies and terms of use.
6.Analytics and Advertising
We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place advertisements on our behalf on other websites and services. For example, we may place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may incorporate tracking technologies into our own Service (including our Website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising“).
As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarise yourself with and consult their privacy policies and terms of use.
While you may disable some tracking technologies by blocking cookies in your browser, you may still see advertising as part of a broader marketing campaign. For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics and Interest-based Advertising, please see the “Information Collected through the Service” and “Your Rights and Choices” sections.
7. Data Transfer
Our Service and Product are operated from and directed toward business customers with a presence in the United Arab Emirates, for exclusive use by their employees and authorised users. Any information we collect may be transferred to, processed, used, handled, and stored in the United Arab Emirates and other jurisdictions. Data protection laws in the United Arab Emirates and other jurisdictions may differ from those of your country of residence. The information we collect is governed according to United Arab Emirates law.
By using the Service or Product, you consent to the transfer, processing, use of, handling, and storage of information about you in the United Arab Emirates and other jurisdictions as described in this Privacy Policy. For personal data transferred from Europe or the United Kingdom, we will provide appropriate safeguards, such as through the use of standard contractual clauses.
8. Additional Important Information
Security. We use organisational, technical, and administrative measures designed to protect information about you from loss, theft, misuse, and unauthorised access, disclosure, alteration and destruction. However, no information security program or transfer via the internet is entirely secure and we cannot guarantee the security of information about you.
Use by Minors. We do not direct any of our services to children. We do not knowingly collect personal information from children under 16. We also do not knowingly sell the personal information of minors. If you are a parent or guardian and believe we have violated this provision, contact us at privacy@qashio.com.
Changes to this Privacy Policy. We reserve the right to change and reissue this Privacy Policy at any time by posting an updated version. Your continued use of our Service or Product indicates your consent to the Privacy Policy then posted. If we have an existing relationship with you, you represent a business customer, or if you are an employee or authorised user, we may provide you or the business customer notice through our Website or your Qashio Account; or provide notice directly to you using the Contact Data provided to us. If we do not have an existing relationship with you—for instance, if you only visit our Website—any notice we provide will be posted to our Website. Any privacy notice is effective upon posting or when it is provided to you.
9. Your Rights and Choices
Qashio Account. The information in your Qashio Account is governed by our agreements with the applicable business customer. You may access, update, or delete certain information within your Qashio Account through the Platform, provided that the business customer will make the ultimate decision around the processing. The business customer’s administrator is responsible for your Qashio Account and Cards associated with the business customer. The business customer administrator has the ability to grant, restrict, suspend, or terminate your access to or use of the Product. The administrator can also access information about you on Product, access and retain information we have stored on its behalf, and limited your ability to edit, modify, delete, or use information associated with your use of the Product. Please note that if you delete information through your Qashio Account, we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Tracking Technology Choices.
Please be aware that if you disable or remove tracking technologies some parts of the Service and Product may not function correctly.
Analytics and Interest-Based Advertising. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb.
The companies we work with to provide you with targeted ads in connection with the Service are required by us to give you the choice to opt out of receiving targeted ads. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.
Communications.
Please note that your opt out is limited to the email address or phone number used and will not affect subsequent subscriptions.
Unlinking Platforms. If you have linked your Qashio Account with certain other services, such as Slack or QuickBooks, you may unlink your accounts at any time by visiting your Qashio Account settings. Please note that unlinking your accounts will not affect any information previously shared through the linking. Qashio is not responsible for the data practices of any other entities, and we recommend that you carefully review their privacy policies and terms of use.
10. Contact Us
If you have any questions about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:
By email: privacy@qashio.com
By mail:
Qashio Software House Limited, P.O. Box 417619, Dubai, United Arab Emirates
If you experience any difficulties accessing the information in this Privacy Policy, please contact us at privacy@qashio.com.
11. Additional Disclosures for Data Subjects in Europe
Roles.
Data protection laws in Europe distinguish between organisations that process personal data for their own purposes (known as “controllers”) and organisations that process personal data on behalf of other organisations (known as “processors”). Qashio acts as a controller with respect to personal data collected as you interact with our Service. For the Product, Qashio acts as a controller, and in certain instances may act as a processor on behalf of a business customer, which is the controller,. Any questions that you have relating to the processing of personal data by Qashio as a processor should be directed to the relevant business customer.
Lawful Basis for Processing.
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners, or business customers; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate safeguards, such as standard contractual clauses.
Your Data Subject Rights.
You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorised by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, please contact us as set out in the “Contact Us” section above and specify which right you are seeking to exercise. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request. If personal data about you has been processed by us as a processor on behalf of a business customer and you wish to exercise any rights you have with such personal data, please inquire with our business customer directly. If you wish to make your request directly to us, please provide the name of our business customer on whose behalf we processed your personal data. We will refer your request to that business customer, and will support them to the extent required by applicable law in responding to your request.
Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you may contact us at privacy@qashio.com. You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.