Tawasal Privacy Policy

Effective Date July 15, 2020

We respect the privacy rights and data protection rights of our users and recognize the importance of protecting the personal information we collect about you. Our Privacy Policy is designed to help you understand what information we collect and how we use and share that information.

For the purposes of this Privacy Policy, ‘Tawasal,’ ‘we’, ‘us’ and ‘our’ refers to Tawasul Information Technology LLC, and ‘you,’ ‘Data Subject’ refers to you, the user of the our cloud-based messaging services (the ‘Services’).

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY ALL THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS AND CONDITIONS. IF YOU DO NOT AGREE TO SUCH TERMS, EXIT THIS PAGE AND DO NOT ACCESS OR USE THE SERVICES.

Tawasal may be like as Data Processor (if we processing your personal data received from third-party) or Data Controller (if we collect your personal data).

  1. What Is Personal Data?

When you use our Services, you may provide information to us which may include your personal information, which is information that may reasonably be used to identify you, such as phone number, IP-address, online identifiers, username, image, geolocation, and other information voluntary provide to us (Personal Data).
Non-Personally Identifiable Information is information that does not identify a specific person. This type of information may include URL (Uniform Resource Locator), mobile carrier information, mobile device information, app data, usage data operational system version information, or aggregated data that doesn’t constitute Personal Data.

  1. Types of Data We Process

Account Information

For using our Services, you need to create an account. While you create an account, you provide to us your phone number. Phone number is used to provide the Services to you. You may optionally add other information to your account, such as name, picture, short bio, etc. Please note, this information may be visible for other users of our Services.

Messages

Tawasal is a cloud messaging service, it means that we store all data in your chats on our servers. You can get access to your chats and media files from any of your devices without backups by third-party services. All your data is encrypted. Encrypted keys stored on secure servers in other countries, that allows us to keep your data safe from interference by third parties.
We allow to use public chats and channels in our Services. All your messages, media posted on public chats and channels is available for other users. We also encrypt data in public chats.
Tawasal allow use bots by third parties in the Services. Bots are program look as user with special interface (menu). Tawasal is not responsible for the third-parties’ bots. When you voluntary iterate with third-parties’ bots they may access to your Personal Data (username, phone number, picture). Please be cautious while you iterate with bots and providing them your information. On cases of abuse and violations please contact us as defined in the Contacts Us section.

Contacts

We always ask for the permission before syncing contacts on your device. Tawasal use phone numbers as identifiers of its users. Tawasal can discover which contacts in your device are Tawasal users.
Once we have received your consent to use your contacts, we synchronize your contacts to identify Tawasal users and display contact name correctly while you use our Services. We synchronize your contacts only phone number and name, we do not use other data from your contact. We do not use your contact details for purposes other than those specified in this paragraph. We can use the total number (in anonymized way) of your contacts to record the average number of Tawasal user contacts.
You can voluntary invite your contacts to use our Services via in-app-link.

Usage Data

We may also collect information that your device sends whenever you use our Services. When you use the Services this Usage Data may include type of device, IP address, operating system, unique device identifiers, duration of session, errors, crashes, length of use, our Services logs, and other diagnostic data. We use this data for improving our Services and statistic purposes only.

Location Data

We may use and store information about your location if you give us permission to do so. We use Location Data to provide features of our Services and for security purposes (only to allow you to share your location, include among other users of the Services).

Information You Provide Through Our Support Channels

The Services also include customer support, where you may send any question regarding the Services. If you speak to our representatives directly, by chat, email or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem and any other information that would be helpful in resolving the issue.

Tracking

We use tracking technologies to track the activity on our Services and hold certain information. We do monitor aggregated activity data on our infrastructure but it is not personal tracking. We perform this tracking to improve our Services and do not use the data collected for marketing and advertising purposes.

  1. Privacy Principles

Tawasal has five key principles when it comes to collecting and processing Personal Data:
a) processed fairly, lawfully and securely;
b) processed for specified, explicit and legitimate purposes in accordance with the Data Subject’s rights and not further processed in a way incompatible with those purposes or rights;
c) adequate, relevant and not excessive in relation to the purposes for which they are collected or further processed;
d) accurate and, where necessary, kept up to date; and
e) kept in a form, which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data were collected or for which they are further processed.

  1. Legal Ground for Processing Your Personal Data

We process your personal data on the ground that such processing is necessary to further our legitimate interests including:
• We need to perform a legal contract with you;
• You give us permission to use Personal Data in some ways;
• The processing is in our legitimate interests and it’s not override your rights;
• To comply with the law.

  1. Processing Your Personal Data

Information collected through the Services will be used for the purposes described in this Privacy Policy or elsewhere on the Services.
This may include:
• To provide and maintain our Service (include, messages, media and files, to any devices of your choosing without a need for you to use third-party backups or cloud storage, advanced and new features);
• Processing and completing transactions relating to the Services;
• Requesting feedback about your use of the Services, our products and other news and promotions we think will be interest to you;
• Responding to your emails, questions, comments, requests and complaints to provide customer service;
• To monitor and analyse the Services usage and trends;
• To perform analytics and to increase the Services’ functionality;
• To improve the security of your account, investigating and preventing fraudulent transactions and other illegal activities;
• To send notifications regarding important changes to the Services;
• Use for the purpose for which the information was collected; and
• To send your confirmations, updates, security alerts, additional information about our Services and support, and otherwise assist with your use of the Services.

Tawasal doesn’t use your data for ad targeting or other commercial purposes. Tawasal only stores the information it needs to function as a secure and feature-rich cloud service.

  1. Data Sharing and Transfer

Other Tawasal Users

When you communicate with other users of Tawasal, bots, public chats, groups, you are sharing your Account Information and Messages data with such users, bots, chats, groups.

Law Enforcement Authorities

We may also share your Personal Data to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
Service Providers. We may share your personal information with third-party service providers to permit such parties to provide services that help us with our business activities, which may include assisting us with hosting, or providing, maintaining and improving the features and functionality of the Services, to detect, prevent, or otherwise address fraud or security or technical issues.

Business Transaction

If Tawasal is involved in a merger, acquisition or asset sale, your Personal Data is transferred and becomes subject to a different Privacy Policy.
Your information, including Personal Data, may be transferred to servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside the United Arab Emirates (UAE) and choose to provide information to us, please note that we transfer the data, including Personal Data, to the UAE, France or other jurisdictions deemed not have an adequate level of data protection deemed by the competent authorities of your residence.
We may also share aggregated or anonymized information with third parties for other purposes. Such information does not identify you individually, but may include usage, viewing and technical information.

  1. Storing Data

All data is stored in third-party data centres. The security of your Personal Data is important to us. We limit access to Personal Data to employees who we believe reasonably need to come into contact with that information to provide the Services to you or in order to do their jobs. We take reasonable technical and organisational measures to protect your personal data to prevent loss, misuse, unauthorized access, alteration and destruction. However, we cannot guarantee its absolute security. While there is always some risk involved in transmitting information over the Internet, we strive to protect against the misuse of any Personal Data we receive from you via the Services.

  1. Data Retention

We store your data at the time of the Services delivery (while your account is active), however, we will retain and use your information as necessary to comply with our legal obligations, government auditing requirements, resolve disputes, and enforce our agreements. At the end of such period, we may, at our sole discretion, delete such data (include Personal Data) without notice to you.
We will continue to store anonymous or anonymized information, such as usage of the Services, in order to improve our Services.

  1. Your Privacy Rights

Upon request the Tawasal will provide you with information about whether we hold any of your Personal Data. You may access, correct, or request deletion of your personal information by logging in to your account and updating your personal information and confirming it by selecting the save button or contacting us at info@tawasal.ae. We will respond to your request within a reasonable timeframe. Please note, this right is subject to certain exceptions, including if we need to comply with a legal obligation or complete a transaction for which we collected the information.
Tawasal acknowledges that you have the right to access your Personal Data. Tawasal has no direct relationship with the individuals whose Personal Data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should use application settings or direct their query to the client support at info@tawasal.ae. If requested to remove data, we will respond within a reasonable timeframe. We will retain Personal Data we process on behalf of our users for as long as needed to provide the Services to our users.
You have the right to access information held about you. You also have the right to ask us to update and correct any out-of-date or incorrect Personal Data that we hold about you free of charge.
Please note that we will try to verify your identity via the email address or other information such as phone number that is associated with your request before deleting your account and your personal information. If another person makes this request on your behalf, please note that we will verify your identity and require them to prove that they have your written authorization to make the request on your behalf.

  1. Children’s Privacy

Our Services is a general audience service, but we restrict of the Service to individuals under the age 18 without parent/guardian consent. We do knowingly collect, maintain, or use Personal Data from children under the age of 18 without parent/guardian consent. If we discover that we have unknowingly collected personal information from these children, we will delete it. If you believe we have collected personal information from a child, please contact us at info@tawasal.ae.

  1. EEA Resident Rights

In this Section we have summarized the rights that you may have under the General Data Protection Regulation 2016/67 (GDPR). Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for full explanation of these rights.

Your principal rights under GDPR are:
• the right to access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to object to processing;
• the right to data portability;
• the right to complain to a supervisory authority; and
• the right to withdraw consent.

You have the right to confirmation as to whether we process your Personal Data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

  1. Privacy Notice for California Residents

If you are a resident of the State of California and you have provided your personal information (Personal Data) to us, you have certain rights under the California Consumer Privacy Act of 2018 (CCPA). You have the right to request that we disclose what personal information we collect, use, disclose, and sell. Contact us to exercise your right to know. You have the right to request deletion of your personal information we collect and maintain. You can exercise this right by sending to us an email. We will verify requests to exercise your California Privacy Rights.
You have the right not to be discriminated against by us for exercising any of your rights under the CCPA.
We do not disclose your personal information to third parties for the commercial purpose.

  1. Third-Party Links

The Services may include links to other websites whose privacy practices may differ from those of Tawasal. If you submit Personal Data to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy practices of others. Any link to a website owned by third party does not constitute an endorsement, approval, association, sponsorship or affiliation with the linked website, unless specifically stated.

  1. Changes to this Privacy Policy

We reserve the right to change our Privacy Policy at any time. If we make changes, we will post them and will indicate on this page the policy’s new effective date.

  1. Contact Us

If you have any comments or questions regarding this Privacy Policy or wish to report any violation of this Policy, you may contact us via email info@tawasal.ae.

Data Controller
Tawasul Information Technology LLC
Address: Al Montazah Tower B, 5th Floor, Office 501, Abu-Dhabi, UAE.
Email: info@tawasal.ae