Effective Date: September 26, 2024

This Privacy Policy ("Policy") describes how Dhow International Holding Company (W.L.L.) ("Dhow", In accordance with applicable data protection regulations in Kuwait, particularly in compliance with the Data Privacy Protection Regulation resolution number 26 of 2024 (the “DPPR”) issued by the Communications and Information Technology Regulatory Authority (“CITRA”)."we", "us", or "our") operates data collection and processing when you use this website (the "Website"). 

We may collect the following data and information when you use the Website:

• Personal Data and Information: We may collect personal information that you voluntarily provide to us, such as your name, email address, phone number, and company affiliation. This Personal Data and information can be collected through contact forms or other means of communication.
• Non-Personal Data and Information: We may also collect non-personal Data and information that is automatically collected when you use the Website, such as your browsing activity, IP address, and device information. This Data and information are used to improve the functionality of the Website and understand user behavior.
• Use of Cookies and Consent: Some of the information described above, including certain personal data, may be collected through cookies or similar tracking technologies. Cookies that are not strictly necessary, especially those used to collect personal data, will only be activated with your prior consent. You can manage your cookie preferences upon when you first visit the Website.

We may use the Personal Data and information we collect for the following purposes:

• To respond to your inquiries and requests
• To improve the Website and its content
• To send you information about Dhow and its services where permitted or with your consent.
• To comply with legal and regulatory requirements

Your personal information will only be used for the specific, legitimate, and lawful purposes for which it was originally collected, in accordance with the DPPR.

We may share your information and personal data with third-party service providers who assist us in operating the Website and delivering our services to you. These service providers are contractually bound by data processing agreements that require them to handle your information and personal data securely and confidentially. We do not share your personal data and information with any third party for marketing purposes without your prior consent.

If we intend to transfer your personal data outside of Kuwait, we will notify you in advance. Such transfers will only take place where appropriate safeguards are in place, including obtaining any required approvals from CITRA or using standard contractual clauses approved for international data transfers. We also maintain a record of all disclosures to third parties as part of our commitment to data protection.

We will retain your information and personal data for as long as necessary to fulfill the purposes described in this Policy or as required by applicable laws and regulations.

We maintain personal data in a form that allows the identification of individuals only for as long as necessary to fulfill the purposes for which the data was collected.

We may anonymize or delete data when no longer required or upon the expiration of the contractual relationship with you.

We maintain detailed records of our personal data processing activities in compliance with applicable data protection laws.

Personal data will be securely stored and deleted or anonymized when no longer needed. We will also delete personal data (i) upon withdrawal of consent, (ii) if the data is no longer necessary for the requested services, or (iii) if the end user is no longer involved in the services for which the data was collected.

We maintain records of processing activities, which are available for review by CITRA upon request.

The Website may use cookies to store information about your preferences and to personalize your experience. You can control cookies through your web browser settings.

Where required, we will obtain your consent for the use of cookies that track personal data.

We take reasonable steps to protect your information and personal data from unauthorized access, disclosure, alteration, or destruction. However, no website or online service can be 100% and completely secure, and we cannot guarantee the security of your information and personal data.

We implement appropriate technical and organizational measures to protect personal data against unauthorized or unlawful processing, accidental loss, damage, or destruction. We apply industry-standard security measures including encryption to protect personal data in transit and at rest, enforcement of strict access controls, and regular monitoring of our systems for vulnerabilities.

In the event of a personal data breach, we will within twenty-four (24) hours of becoming aware of the breach, notify the CITRA. The notification will include the nature of the personal data breach, including the categories and approximate number of data subjects and data records concerned, the likely consequences of the breach, and the measures taken or proposed to address the breach and mitigate its possible adverse effects.

We will also notify you in the event of such breach. This notification will be provided in clear and plain language and will include the same information and personal data shared with CITRA, as well as the contact details of our Data Protection Officer or designated contact point.

However, we may not be required to notify you if appropriate technical and organizational protection measures—such as encryption—were applied to the affected personal data, rendering it unintelligible to unauthorized parties.

In all cases, we will adopt appropriate subsequent measures to ensure that the risks to your rights and freedoms do not escalate and to prevent any recurrence of such breaches.

The Website is not directed to children under the age of 18. We do not knowingly collect personal data and information from children under 18 without the explicit consent of their parents or legal guardian.

We do not knowingly collect personal data from anyone under 18 without the explicit consent of a parent or legal guardian. If we become aware that such data has been collected, we will delete it immediately. Guardians may withdraw their consent at any time, and the child’s data will be fully erased.

You have certain rights regarding your personal data and information, including the right to access, correct, and delete your information and personal data. You can also object to the processing of your information and personal data. You may also withdraw your consent at any time.

You have the right to request data portability and to request a restriction of processing.

To exercise any of these rights, you can submit your request by contacting privacy@al-dhow.com, and we will process your request within the timeframe required by CITRA.

You have the right to:

• Access your personal data
• Rectify any inaccurate or outdated information or personal data
• Erase your personal data (Right to be Forgotten) 
• Restrict the processing of your personal data
• Object to data processing
• Transfer your personal data
• Not be subject to automated decision-making, including profiling.

You also have the right to withdraw your consent at any time, and we provide an easy-to-use process for you to withdraw consent or disable the collection, use, processing, or disclosure of your personal data.

For detailed information on how we collect, use, and share your Personal Data, including how to exercise your rights and applicable timeframes, please refer to our privacy notice available on our website.

We may revise this Policy at any time by updating this Policy. You are encouraged to review the Website periodically to stay informed of any changes since you should be bound by any revisions.

If material changes are made to this Policy, we will provide prior notice and, where appropriate, obtain renewed consent.

Any changes and/or updates that affect the way we process personal data will be communicated clearly and in advance.

We consider the impact of any changes in our products, systems, or services on the processing of personal data and update this Policy accordingly.

If you have any questions about this Policy, please contact us by email at privacy@al-dhow.com.