We at Information Technology for Sharing Solutions LLC, a limited liability company established in the Kingdom of Saudi Arabia, having its headquarter at 7129 Ath Thumamah Rd Al Rabie Dist. Unit No 4 Riyadh 13315 – 3694, registered at Riyadh Commercial Register office under number 1010672741 hereinafter referred to as (“Gazal”), are strongly committed to transparency, and we want you to understand how we collect, use, share and protect your information. This Privacy Notice (” Privacy Notice“) describes how Gazal handles information in connection with Gazal’s websites and related mobile applications and services (collectively, the ” Services“), and when you otherwise interact with us. When specified, this policy also describes our data practices related to Juicers. Please also read our User Terms and Conditions which sets out the terms governing the Services from the following link: Terms of Service – GAZAL
We reserve the right to change this Privacy Notice from time to time. If Gazal makes changes to this Privacy Notice, the updated Privacy Notice will be made available through our Services and if we make any material changes to this Privacy Notice, we will provide a prominent notice and may also contact you directly by email or another method.
The Types of Information We Collect
We collect or receive information in different ways. The types of information we collect or receive depends on how you use and interact with our Services. In many cases, you can choose the information you provide to us, although certain information (such as account information) is required for us to provide the Services and if it is not provided, we will not be able to provide the Services. We use and disclose this information for the purposes described further below. The types of information we collect include:
- Account Information such as your name, e-mail address, telephone number, date of birth, gender, address details, and payment information such as your credit card details. In order to use certain products, we may also require you to provide photos of your government issued driver’s license (front and back)
- We collect and process location data when you sign up and use the Services. For example, to accurately show you Gazal vehicles near your location, it is necessary to collect and record the physical location of your device. Data such as the location of the vehicle, the routes taken by the moped, bike, scooter, or other vehicle and its usage status are also necessary to provide the Services. Gazal also collects location data directly from Gazal’s vehicles including when a Gazal’s user is riding, such as trip information.
- When you use certain products (e.g. mopeds) that require a government-issued driver’s license and the use of a helmet or other legally required protective gear, we will ask you (and your passenger, if applicable) to take a selfie which we collect, and we may collect images and/or video footage of your ride.
- If you link, connect, or login to Gazal with a third-party service (e.g. Facebook, Instagram,……), the third-party service may send us information such as your profile information from that service.
- When you ask for customer service, support or other assistance, you can choose to provide us with your contact information so we can better respond to your requests and we may keep information about your engagement with our support services.
- We collect information you share on the Services such as when you participate in communities or other forums, or comment on our social media accounts or blog entries. Depending on your camera or photo settings, Gazal will receive information you choose to send us such as photos of Gazal’s parked vehicles.
- We receive information about you when we use third-party partners such as marketing and advertising partners, such as social media networks.
- provide the Services to you at your request including to manage your account and ride history;
- confirm your government-issued driver’s license (if provided) is valid, not currently linked to any other Gazal account, and has not expired;
- verify your selfie matches your government issued driver’s license such as by using facial recognition technology (if any);
- monitor, track and service Gazal’s vehicles, including when they are in use by you. Where applicable, this includes collecting images after you finish your ride;
- riders and passengers may wear a helmet in order to activate the bonus program;
- process payments, or subscriptions and any discounts or special offers such as free unlocks;
- communicate with you about your account, interactions or transactions including service- related announcements such as changes to our policies. As allowed by Laws, regulations and policies in force in the Kingdom of Saudi Arabia, we may also send you surveys or marketing communications on behalf of Gazal and/or third parties, including information about features and enhancements to our Services;
- personalize advertisements to you (for more information, see the “Advertising and Analytics” section below);
- optimize, develop and improve our Services, including for creation and training of machine learning models to optimize, develop and improve our Services. To do this we may use third party analytics and statistics providers to understand how the Service is being used and to help us to improve the Services;
- where necessary, to comply with our legal obligations including to meet regulatory or local law requirements;
- detect, investigate, and prevent activities that may violate Gazal’s policies or User Terms and Conditions or be illegal; and
- share and collaborate with third parties such as universities, local government authorities and other third parties to build or improve transportation infrastructure, as described in the “Who Do We Share Your Information With?” section below.
Who Do We Share Your Information With?
We share your information with Gazal’s affiliated companies, our service providers, other third parties where it is necessary to perform the User Terms and Conditions and as described in this Privacy Notice. In particular, we share your information with:
- Our service providers and partners: We share your information with our trusted service providers, partners, and their personnel who provide services to Gazal such as hosting data and our infrastructure, providing ID verification services, processing payments, supporting and improving the Services, performing customer service, or providing marketing and advertising services. For example, we share information with credit card issuers in order to process your payments and refunds.
- Collaborations with third parties: After removing certain identifiers, such as your name, phone, and e-mail address (where provided), and combining the resulting information with similar information from other users, Gazal may use, license, and share your information, including individual trip records and trip location history, with third parties for research, business or other purposes. For example, Gazal partners with universities to collaborate on research projects such as understanding traffic and travel patterns in a city.
- Government, regulatory and law enforcement agencies: We may share your information if we believe in good faith that it is reasonably necessary to do so for legal reasons, related to Laws, regulations and policies’ requirements in force in the Kingdom of Saudi Arabia or as part of a judicial process or to detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues or to prevent harm or injury to you, members of the public, our staff, other third parties, or ourselves; or if we need to do so to defend our legal rights or property, to take action regarding illegal activities or traffic offenses, or to enforce our contracts, such as our User Terms and Conditions.
- Integrated Partners: We share your information with third party services which integrate or provide access to Gazal vehicles and/or the Services.
- Cities, local authorities and public transport operators: We share your information with these recipients where necessary to fulfill conditions of our license or where necessary to operate in a particular city or location or for the purposes of city planning and understanding mobility insights. This may include the recipients contacting riders to request participation in surveys and integration into public transport operators’ apps and trips planning apps. The data shared for these purposes includes:
- Account information, such as Gazal user identifier, name, email address, telephone number, government-issued driver’s license, date of birth, and gender;
- Trip data, such as trip ID number, date and time of trip, distance of trip and duration of trip;
- Location data, such as location of the scooter and the routes taken by the scooter;
- Survey data, such as Gazal user identifier, survey date, survey type and question and answer (in the case of user experience surveys only).
- Pseudonymized data such as vehicle ID, vehicle status, trip ID and waypoint.
- Gazal affiliates: We may share your information with Gazal affiliate companies to help provide, maintain and improve the Services. As we grow, we may expand our corporate family by establishing local subsidiaries or other affiliates as needed, to help us provide or market the Services.
- Business re-organization: We may also share your information as part of a sale, merger, change in control, or in preparation for any of these events.
Our Legal Basis for Using Your Information
In Kingdom of Saudi Arabia, we are required to specify the purposes for which we process your personal information and the legal bases which we rely on to do this. Gazal relies on a number of legal bases to collect, use, share, and otherwise process your information for the purposes described in this Privacy Notice, including where:
- it is necessary to provide the Services and perform our obligations in accordance with the User Terms and Conditions. For example, we cannot provide the Service unless we collect and process basic information about you and your location;
- you have provided your consent to us processing your information (in which case you may revoke your consent at any time);
- it is necessary to comply with a legal obligation, including, for example, responding to government agency or law enforcement information requests or to establish, exercise or defend legal claims;
- to protect vital interests of our users, staff, and members of the public both on and off the Services;
- it is permitted by law, we may process data in the public interest; and / or
- the processing is necessary for the purposes of Gazal’s or a third party’s legitimate interests, provided that we have balanced these against your fundamental rights and interests.
How Long We Keep Information
We keep your information for as long as is reasonably necessary to provide the Services to you or until your account is deleted, whichever is longer, subject to any longer period as may be required by applicable law or notified to you. Examples of some of our retention periods are set out below.
When you delete your account, it may take us additional time to partially delete your information from our databases and system logs. We may also retain some of information from deleted accounts to prevent fraud, collect fees, enforce the User Terms and Conditions, to comply with our legal obligations or enforce our legal rights.
Some of these rights apply generally might apply:
Right to object (marketing) – You have the right to object to processing for direct marketing purposes at any time.
Right to object (legitimate interest) – Where we process your information based on legitimate interests, you can object to this processing in certain circumstances. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.
Right of access – You can access much of your information by logging into your account. You can also request a copy of the information we have about you and information explaining how the information is used.
Right of rectification – You have the right to request that we rectify inaccurate information about you.
Right to restrict processing – You have the right, in certain cases, to temporarily restrict the processing of your information by us, provided there are valid grounds for doing so.
Right to data portability – You may have the right to receive certain of your information in a structured, commonly used and machine-readable format and to transmit such information to another controller.
Right to withdraw consent – Where you have previously provided your consent, such as to send you direct marketing, you have the right to withdraw consent at any time. However, this will not affect the lawfulness of the processing based on consent before its withdrawal. Furthermore, even in case of a withdrawal, we may continue to use your information as permitted or required by law.
Right to provide guidance on the management of your data after your death – You have the right to provide us with specific guidance on the storage, deletion of communication of your personal data after your death.
Please get in touch with us as set out in the Contact section below if you would like to exercise any of these rights or in case you should have any concerns about how we process your information. For security purposes, we may require that you follow certain steps in order to verify that you are the owner of a Gazal account. For example, we may require that you have a verified email associated with your Gazal account and that you get in touch with us using the verified email associated with your Gazal account.
Your Choices and How You Can Manage Your Information: We believe you should have choices about the collection, use and sharing of your information. If you do not want Gazal to collect your information, please do not use the Services.
Emails and Other Communications: If you would like to change the types of communications you receive from us, including opting out of promotional communications from us, you may do so at any time by updating the communication preferences specified in your account profile. We may continue to send non-promotional communications and other information about your use of the Service.
Accessing and Managing Your Information: If you have an account with Gazal, you can review, change or delete your information by logging into your account and editing your profile. You can change your mobile phone number or email address by using our in-app change feature. You can delete your Gazal account at any time by submitting a request to us at [email protected] or by using the in-app “Submit a Request” feature.