We wrote this Policy to help you understand what information we collect, how we use it and what choices you have about it.
This Policy applies to those who provide information to Back9 in connection with an application to use our apps (“Our Apps”) or services, or whose information Back9 otherwise receives in connection with its services (such as contact information of individuals associated with partners). All those subject to this Policy are referred to as “users” for purposes of this Policy.
The data controller for the information you provide or that is collected by Back9 or its affiliates is:
Back 9 Solutions General Trading LLC, 301 Al Maktab Building, Street 13, Al Barsha 1, Dubai, United Arab Emirates.
[If you live in the European Union or elsewhere, the data controller is:
Back 9 Digital LLC, Coliemore House, Coliemore Road, Dalkey, Co. Dublin, Ireland
We process personal information inside and outside of the United States. Back9 transfers information of users outside the United States on the basis of mechanisms approved under applicable .
What information we collect from you
Information you provide to us. We receive and store any information you enter on Our Apps or give us in any other way. This includes information that can identify you (‘Personal Information’), including your first and last name, telephone number, postal and email addresses, login name and password, payment or banking information (such as credit card number, cardholder name, and expiration date) including related payment verification information, birth date, photo and signature. You can choose not to provide information to us, but in general some information about you is required in order for you to register as a member; book services; complete a member profile; ask us a question; or initiate other transactions on our site.
Information from Other Sources. We also may periodically obtain both personal and non-personal information about you from affiliated entities, business partners and other independent third-party sources (including marketing service providers), publicly available sources, and add it to our account information. Examples of information we may receive include: updated delivery and address information, purchase history, preferences, and demographic information.
Automatic Information. In addition to log data, we collect some information about your device when you use Our Apps, including type of device, operating system, settings, unique device identifiers and crash data that helps us understand when something breaks. We also may collect information about your online activity, such as services viewed and bookings made. Our goals in collecting this automatic information include helping customize your user experience and inhibiting fraud.
For more information, please see Cookies, similar technologies & advertising.
How we use your information
Information you give us
We will use information you give to us in the following ways:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with any information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you.
- to notify you about changes to our service; and
- to ensure that content from Our Apps is presented in the most effective manner for you and for your devices.
Information we collect about you
We will use the information that we collect about you in the following ways:
- to administer our Apps and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Apps to ensure that content is presented in the most effective manner for you and for your device;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep Our Apps safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
- to make suggestions and recommendations to you and other users of Our Apps about goods or services that may interest you or them.
Information we collect from other sources
We may combine this information with information you give to us and information we collect about you. We may use this combined information for the purposes set out above (depending on the types of information we receive).
With whom we share your information
We may share your information with the following entities:
- Third-party vendors who provide services or functions on our behalf, including credit card processing, business analytics, customer service, marketing, distribution of surveys, and fraud prevention. We may also authorize third-party vendors to collect information on our behalf, including as necessary to operate features of our Apps or to facilitate the delivery of online advertising tailored to your interests. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose. They are also required to follow the same data security practices that we ourselves adhere to.
- Business partners with whom we may jointly offer products or services, or whose products or services may be offered on our website. You can tell when a third party is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we may share information about you, including your personal information, with those partners. Please note that we do not control the privacy practices of these third-party business partners.
- Companies within our corporate family. We may share your personal information with our parent company and corporate affiliates. This sharing also enables us to provide you with information about products and services which might interest you. To the extent that our parent company and corporate affiliates have access to your information, they will follow practices that are at least as restrictive as the practices described in this Policy.
- With your consent. Back9 may share your information other than as described in this Policy if we notify you and you consent to the sharing.
We also may share your information:
- In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we reserve the right to raise or waive any legal objection or right available to us.
- In connection with a corporate transaction, such as a merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
We also may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors or members Our Apps have. This information does not contain any personal information and is used to develop content and services we hope you will find of interest.
Other than as set out above, you will be notified when Personal Information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.
Grounds for Processing
The GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds. As described below, Back9 processes the information of EU users based on one or more of the grounds specified under the GDPR:
- The processing is necessary to provide the services and features you request.
- Back9 must collect and use certain information in order to provide its services. This includes User profile information that is necessary to establish and maintain your account, including to verify your identity; enable communications with you about your bookings and accounts; and to enable you to make payments or receive earnings. Collection and use of this information is a requirement for using Back9’s apps.
- The processing is necessary for Back9’s legitimate interests.
- Back9 collects and uses personal information to the extent necessary for its legitimate interests. This includes collecting and using information:
- To maintain and enhance our users’ safety and security and to prevent, detect and combat fraud in connection with the use of our services.
- To provide customer support.
- To optimize our service and develop new services. For research and analytical purposes. This includes, for example, analyzing usage trends to improve the user experience and enhance the safety and security of our services.
- For direct marketing purposes. This includes, for example, analysing data to identify trends and tailor marketing messages to user needs.
- To enforce Back9’s Terms of Service.
- Back9 collects and uses personal information to the extent necessary for its legitimate interests. This includes collecting and using information:
- Back9 may collect and use your information on the basis of your consent. You may revoke your consent at any time. If you revoke your consent, you will not be able to use any service or feature that requires collection or use of the information we collected or used on the basis of consent.
- We rely on consent in connection with data collections or uses that are necessary to enhance the user experience, to enable optional services or features, or to communicate with you.
How you can access your information
You can access and update your contact information by visiting your settings. You can close your account by contacting us at the email address listed below. Please note that after you close an account, you will not be able to sign in or access any of your personal information. However, you can open a new account at any time. Please also note that we may retain certain information associated with your account, including for analytical purposes as well as for record keeping integrity.
Your options with respect to collection and use of your information
You have options in relation to the information that we have about you described below. To exercise these options, please contact email@example.com or firstname.lastname@example.org
- You can choose not to provide us with any information, although it may be needed to avail the Services.
- You can have your information updated, corrected or deleted. You can update your information in your Settings. If you have problems updating the information or if you would like us to delete it, contact us.
- You can access the information we hold about you. We’ll usually share this with you within 30 days of you asking us for the information .
- You will be given the opportunity to unsubscribe from commercial emails in any such message that we send you. If you are a registered member, you can also modify your choice at any time your Settings. Please note that we reserve the right to send you other communications, including service announcements, administrative messages, and surveys relating either to your account or to your transactions on this site, without offering you the opportunity to opt out of receiving them.
- You may have the opportunity on Our Apps to receive alerts. You may discontinue these notifications at any .
- Object to us processing your information. You can ask us to stop using your information, including when we use your information to send you marketing emails or push notifications. If you opt out of receiving marketing messages from us, we may still send you newsletters and updates about your account. We only send you marketing material if you’ve agreed to it, but if you’d rather we don’t, you can easily unsubscribe at any time.
- Have the information you provided to us sent to another organization, where we hold this information with your consent or for the performance of a contract with you, where it’s technically feasible.
Retention of Information
We retain information until such information is no longer necessary to provide our services, enable customer support, enhance the user experience or other operational purposes. You may request deletion of your account at any time through your Settings in Our Apps.
Following such request, we will delete the information that it is not required to retain. In certain circumstances, we may be unable to delete your account, such as if there is an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete your account as described above.
We may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, if we shut down a user’s account because of unsafe behavior or security incidents, we may retain certain information about that account to prevent that user from opening a new Back9 account in the future
How we protect your information
We are committed to protecting the information we collect. While no mobile application can guarantee security, we have implemented appropriate administrative, technical, and physical security procedures to help protect the personal information you provide to us. For example, only authorized employees are permitted to access personal information, and they may only do so for permitted business functions. In addition, we use encryption when transmitting your sensitive personal information between your system and ours, and we employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to your .
We do not knowingly collect personal information from minors/children under the age of 18. Minors are not permitted to use Our Apps or Our services, and we request that minors under the age of 18 not submit any personal information to Our Apps. Since information regarding minors under the age of 18 is not collected, we do not knowingly distribute personal information regarding minors under the age of 18.
Changes to this Policy
We may update this Policy in the future. We will notify you about material changes to this Policy by sending a notice to the email address you provided to us, sending a push notification to our applications, by placing a prominent notice on our website or a 3rd party website where applicable.
How you can contact Us
If you have questions about either this Policy or Our Apps, please contact email@example.com, or firstname.lastname@example.org