Owner and Data Controller
Telestark FZ-LLC
Dubai Internet City
Dubai
UAE
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data;
unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific
explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage
Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is
mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this
Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the
availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact
the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by
this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the
present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have
the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the
Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes
strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of
persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or
external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications
agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at
any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
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Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process
Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following
legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
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provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
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processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the
Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the
provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are
located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out
more about the place of processing of such transferred Data, Users can check the section containing details about the processing of
Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international
organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures
taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner
using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
-
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until
such contract has been fully performed.
-
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such
purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of
this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as
such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do
so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to
rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to
enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent
activity, as well as the following: Analytics, Remarketing and behavioral targeting, Advertising, Content performance and features testing
(A/B testing) and Tag Management.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the
processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are
displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Cookies or other Identifiers to identify Users or they may use the behavioral
retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside
this Application. For more information, please check the privacy policies of the relevant services.
In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting the
Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device
advertising settings for mobile phones or ads settings in general.
Google Ads Similar audiences (Google Ireland Limited)
Similar audiences is an advertising and behavioral targeting service provided by Google Ireland Limited that uses Data
from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the
remarketing list due to their past use of this Application.
On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.
Users who don't want to be included in Similar audiences can opt out and disable the use of advertising cookies by
going to: Google Ad Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland –
Privacy Policy –
Opt Out. Privacy Shield participant.
-
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track
of User behavior.
Google Analytics (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data
collected to track and examine the use of this Application, to prepare reports on its activities and share them with
other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland –
Privacy Policy –
Opt Out. Privacy Shield participant.
Analytics collected directly (this Application)
This Application uses an internal analytics system that does not involve third parties.
Personal Data processed: Cookies; Usage Data.
Google Analytics with anonymized IP (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data
collected to track and examine the use of this Application, to prepare reports on its activities and share them with
other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within
member states of the European Union or in other contracting states to the Agreement on the European Economic Area.
Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland –
Privacy Policy –
Opt Out. Privacy Shield participant.
Google Ads conversion tracking (Google Ireland Limited)
Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the
Google Ads advertising network with actions performed on this Application.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland –
Privacy Policy. Privacy Shield
participant.
Google Analytics Advertising Reporting Features (Google Ireland Limited)
Google Analytics on this Application has Advertising Reporting Features activated, which collects additional
information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the
Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled,
demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's
Ads Settings.
Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example);
various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland –
Privacy Policy –
Opt Out. Privacy Shield participant.
Google Analytics Demographics and Interests reports (Google Ireland Limited)
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available
demographic and interests Data inside Google Analytics for this Application (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's
Ads Settings.
Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: Ireland –
Privacy Policy –
Opt Out. Privacy Shield participant.
-
Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or
behavior regarding changes to the structure, text or any other component of this Application.
Google Optimize (Google Ireland Limited)
Google Optimize is an A/B testing service provided by Google Ireland Limited ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland –
Privacy Policy. Privacy Shield
participant.
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Remarketing and behavioral targeting
This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use
of this Application by the User.
This activity is facilitated by tracking Usage Data and by using Cookies and other Identifiers to collect information
which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the
Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device
advertising settings for mobile phones or ads settings in general.
Google Ad Manager Audience Extension (Google Ireland Limited)
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland
Limited that tracks the visitors of this Application and allows selected advertising partners to display targeted ads
across the web to them.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland –
Privacy Policy –
Opt Out. Privacy Shield participant.
Google Ads Remarketing (Google Ireland Limited)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that
connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's
Ads Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland –
Privacy Policy –
Opt Out. Privacy Shield participant.
Remarketing with Google Analytics (Google Ireland Limited)
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google Ireland Limited
that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising
network and the Doubleclick Cookie.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland –
Privacy Policy –
Opt Out. Privacy Shield participant.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the
activity of this Application with the Facebook advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States –
Privacy Policy –
Opt Out. Privacy Shield participant.
-
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage Data.
Place of processing: Ireland –
Privacy Policy. Privacy Shield
participant.
Further information about Personal Data
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Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles.
This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes
outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by
third parties. To find out more about the profiling activities performed, Users can check the relevant sections of
this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and
how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
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Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to
the processing of their Personal Data.
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Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried
out on a legal basis other than consent. Further details are provided in the dedicated section below.
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Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain
aspects of the processing and obtain a copy of the Data undergoing processing.
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Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or
corrected.
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Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their
Data. In this case, the Owner will not process their Data for any purpose other than storing it.
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Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure
of their Data from the Owner.
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Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured,
commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any
hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the
User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes
of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular
situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing
at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes,
Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests
can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Cookie Policy
This Application uses Cookies and other Identifiers. To learn more, the User may consult the
Cookie Policy.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising
from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal
personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual
information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this
Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact
information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do
Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within
this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to
the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the
User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number —
allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can
include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses
(Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the
file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the
country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit
(e.g., the time spent on each page within the Application) and the details about the path followed within the Application with
special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT
environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as
described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes
and means of the processing of Personal Data, including the security measures concerning the operation and use of this
Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to
the European Union and the European Economic Area.
Cookies
Small sets of data stored in the User's device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU)
2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Application, if not stated otherwise within this document.