1. INTRODUCTION

Thank you for using GoJolly! Your trust is important to us and we’re committed to protecting the privacy and security of your personal information.

The information that’s shared with us helps us to provide a great experience with the GoJolly Services. This Privacy Policy describes how we collect, use, process, and disclose your personal information, in conjunction with your access to and use of the GoJolly Platform. Unless stated otherwise, this privacy policy describes our privacy practices for all websites, platforms and services that [GoJolly FZC], a private limited company incorporated under the laws of [UAE] with a registered office located at [Address], registered under the company registration number [•] at the [Companies House] operates.

1.1 Definitions

If you see an undefined term in this Privacy Policy (such as “Invitation” or “Platform”), it has the same definition as in our Terms of Service (“Terms”).

1.2 Data Controller

When this policy mentions “GoJolly,” “we,” “us,” or “our,” it refers to [GoJolly FZC] that is responsible for your personal information under this Privacy Policy (the “Data Controller”).

1.3 Applicability to Payments

This Privacy Policy also applies to the payment processing services provided to you through or in connection with your use of the Platform (“Payments Services”) by us or one of our third party payment processors. When using the Payment Services, you acknowledge and agree that you will also be providing your information, including personal information, to us or other third parties, who will be the respective Data Controller (the "Payments Data Controller") of your information related to the Payment Services depending on the nature of your transaction over the Platform.

For example, for (an) Activity, all payment information (including credit card or other payment information) provided over the Platform will not be collected or retained by us and the Payments Data Controller for the Payment Services relating to your transaction over the Platform is Stripe (or such other third party payment processing service that we may use from time to time) and you should carefully review the respective privacy policy at https://stripe.com/en-sg/privacy#personal-data-definition; https://www.tap.company/kw/en/privacy-policy: and (b) Hosts, we will be the Payments Data Controller in respect of your Hosting Experiences over the Platform and the associated receipt of payments and we will collect and store your personal information in accordance with this Privacy Policy.

2. INFORMATION WE COLLECT

There are three general categories of information we collect.

2.1 Information You Give to Us.

2.1.1 Information that is necessary for the use of the Platform.

We ask for and collect the following personal information about you when you use the Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

• Account Information. When you sign up to GoJolly, we require certain information such as your first name, last name, email address, mobile phone number and date of birth.
• Profile and Invitation Information. To use certain features of the Platform (such as booking, creating a gift or creating an Invitation), you may be asked to provide additional information, including your address, phone number, and a profile picture.
• Identity Verification Information. To help maintain a trusted environment, and when required by the applicable laws we may collect identity verification information (such as images of your government issued ID, passport, national identity card, or driving license, as permitted by applicable laws) or other background and authentication information.
• Payment Information. To use certain features of the Platform, we may require you to provide certain financial information (like your bank account or credit card information) to the respective Payments Data Controller in order to facilitate the processing of payments.
• Communications on the Platform. When you communicate with GoJolly or use the Platform to communicate with other Users, we collect information about your communication and any information you choose to provide.

2.1.2 Information you choose to give us.

You may choose to provide us with additional personal information in order to obtain a better user experience when using the Platform. This additional information will be processed based on our legitimate interest or when applicable, your consent.

• Additional Profile Information. You may choose to provide additional information as part of your User Account profile (such as gender, preferred language(s), city, and a personal description). Some of this information as indicated in your User Account settings is part of your public profile page, and may be publicly visible to others.
• Address Book Contact Information. You may choose to import your address book contacts or manually provide your contacts’ information to access certain features of the Platform, like inviting them to use GoJolly.
• Other Information. Additionally, you may choose to volunteer information when you fill in a form, update or add information to your User Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer service team or use other features of the Platform.

2.1.3 Information that is necessary for the use of the Payment Services.

We or the respective Payments Data Controller may need to collect the following information to comply with applicable regulations (such as anti-money laundering regulations) and to provide the Payment Services:

• Payment Information. The respective Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law. If you are a Explorer, we will not process or retain any payment information and you will have to provide this information to the respective third party Payments Data Controller directly to access features of the Platform. Please review the respective third party Payments Data Controllers’ privacy policy for further information on how your information is processed.
• Identity Verification and Other Information. The Payments Data Controller may require identity verification information (such as images of your government issued ID, passport, national identity card, or driving license, as permitted by applicable laws) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable law.

2.1.4 Information We Automatically Collect from Your Use of the Platform and Payment Services.

When you use the Platform and the Payment Services, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Platform and Payment Services.

• Geo-location. When you use certain features of the Platform, we may collect information about your approximate or precise location as determined through information such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. GoJolly may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
• Platform Usage. We collect information about your interactions with the Platform such as the pages or content you view, your searches for Invitations, bookings you have made, and other actions on the Platform.
• Log Data and Device Information. We automatically collect device information and log data when you access and use the Platform, even if you have not created a User Account or logged in. That information includes, among other things: details about how you’ve used the Platform (including whether you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Platform.
• Cookies and Similar Technologies. We use cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers and other similar technologies when you use our Platform, use our mobile app, or engage with our online ads or email communications to collect information. In many cases the information we collect using cookies and other similar tools is only used in a non-identifiable format without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some case we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the Platform or engage others to track and analyse your behaviour on our behalf to improve our Platform.
• Pixels and SDKs. Third-parties, may use cookies, web beacons, and other storage technologies to collect or receive information from our Platform and elsewhere on the internet and use that information to provide measurement services and target ads.
• Do Not Track Function.
• Payment Transaction Information. GoJolly or the respective third-party Payments Data Controller collects information related to your payment transactions through the Platform. This information is necessary to allow the provision of the GoJolly Services.

2.1.5 Information We Collect from Third Parties.

We may collect information, including personal information, that others provide about you when they use the Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the Platform and the Payment Services. We do not control, supervise, or respond to how third parties providing your information process your personal information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

• Third Party Services. If you link, connect, or login to your User Account with a third-party service (e.g. Google, Twitter or Facebook), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that third party service or as authorized by you via your privacy settings on that service.
• Your References. If someone has written a reference or review about you, it may be published on your GoJolly public profile page.
• Background Information. To the extent permitted by applicable laws, we may obtain reports from public records of criminal convictions, sex offender registrations, police records, background or registered sex offender checks (if applicable). We may use your information, including your full name and date of birth, to obtain such reports.
• Referrals. If you are invited to GoJolly, the person who invited you may submit personal information about you such as your email address or other contact information.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Platform through partnerships, or about your experiences and interactions from our partner ad networks.

2.2 Children’s Data.

Our websites and applications are not directed to children, minors, persons under 18 and we do not knowingly collect any personal information directly from such individuals. If you believe that we are processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us at support@GoJolly.io immediately.

3. HOW WE USE INFORMATION WE COLLECT

We may use, store, and process personal information to (a) provide, understand, improve, and develop the Platform, (b) create and maintain a safer and trusted environment (such as to comply with our legal obligations and ensure compliance with GoJolly Policies) and (c) provide, personalize, measure, and improve our advertising and marketing.

3.1 Provide, Improve, and Develop the Platform. We may use your personal information to provide, improve, and develop the Platform such as to:

• enable you to access and use the Platform,
• enable you to communicate with other Users,
• operate, improve, protect, and optimize the Platform and experience, such as by conducting research and performing analytics,
• provide customer service,
• send you service or support messages, updates, security alerts, and account notifications,
• if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the point of collection,
• to operate, protect, improve, and optimize the Platform and experience, and personalize and customize your experience (such as making Invitation suggestions, ranking search results), and facilitate claims, we may conduct profiling based on your interactions with the Platform, your search and booking history, your profile information and preferences, and other content you submit to the Platform, and
• enable your use of our enterprise products, where applicable.

We process this personal information for these purposes given our legitimate interest in improving the Platform and our Users’ experience with it, and where it is necessary for the adequate performance of the contract with you.

3.2 Create and Maintain a Trusted and Safer Environment. We may use the personal information to create and maintain a trusted and secure environment such as to:

• detect and prevent fraud, abuse, spam, security incidents, and other harmful activity,
• conduct security investigations and risk assessments on our own or with third parties,
• verify or authenticate information provided by you (such as to verify your address and Experience Venue or compare your identification photo to another photo provided),
• conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required,
• comply with our legal obligations,
• Resolve any disputes amongst Users and enforce our agreements with third parties,
• enforce our Terms of Service and other policies, and
• in connection with the activities above, we may conduct profiling based on your interactions with the Platform, your profile information and other content you submit to the Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Platform if such processes detect activity that we think poses a safety or other risk to the Platform, our community, or third parties.

We process this personal information for these purposes given our legitimate interest in protecting the Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

3.3 Provide, Measure, Personalise, and Improve our Advertising and Marketing. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:

• send you promotional messages, marketing, advertising, and other information that may be relevant to you based on your preferences (including information about GoJolly or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google),
• personalize, measure, and improve our advertising,
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by GoJolly or its third party partners,
• conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Platform, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be relevant to you,
• enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any User Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have a User Account, and
• invite you to events and relevant opportunities.

We will process your personal information for the purposes described above given our legitimate interest in undertaking marketing activities to offer you products or services that may be relevant to you.

3.4 How the Payments Data Controller uses the Personal Information Collected. We may use the personal information as a part of Payment Services such as to:

• Enable you to access and use the Payment Services and other Platform services.
• Detect and prevent fraud, abuse, security incidents, and other harmful activity.
• Conduct security investigations and risk assessments.
• Conduct checks against databases and other information sources.
• Comply with legal obligations (such as anti-money laundering regulations).
• Enforce payment terms and other payment policies.
• With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

The Payments Data Controller processes this personal information given its legitimate interest in providing and improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

3.5 SMS Terms

For text messaging services, by providing your mobile number, requesting, joining, agreeing to, enrolling in, signing up for, acknowledging, or otherwise consenting to receive one or more text messages (“Opting In”)or using a GoJolly arrangement in which GoJolly sends (or indicates that it may send, or receives a request that it send) one or more text messages (“Text Message Service”), you accept these SMS Terms (“SMS Terms”) and give consent to the handling of your personal information as described in this Privacy Policy, and agree to resolve disputes with us as described in our Terms of Service. Message and data rates may apply.

GoJolly will use reasonable commercial efforts to deliver the text messages to the number you provide through compatible networks. Carriers and GoJolly are not liable for delayed or undelivered messages. The short code we use for some Text Message Services may not be supported on all network carriers.

Opting In

By Opting Into a Text Message Service:

• You expressly authorize GoJolly to send text messages to the mobile phone number provided. You also authorize GoJolly to include marketing content in any such messages.
• You confirm that you are the subscriber to the relevant phone number or that you are the customary user of that number on a family or business plan and that you are authorized to opt In.
• You consent to the use of an electronic record to document your Opt-In. To withdraw that consent or update our records with your contact information, please contact us at support@gojolly.io

After Opting In, in addition to the main messages the service offers, you may receive one or more administrative or welcome messages, such as (in some cases) a request to confirm your Opt-In.

About the Text Message Services and Opting Out

Message and data rates may apply. Unless otherwise noted, Text Message Services send multiple, recurring messages. GoJolly may terminate any Text Message Service or your participation in it at any time with or without notice, including, for example, before you have received any or all messages that you otherwise would have received, but these SMS Terms still will apply.

For additional help regarding our Text Message Service, contact us at support@gojolly.io .

3.6 Your Choices

You can choose the promotional messages that you wish to receive.

• You can limit the information you provide to GoJolly. Participation in promotions and marketing programs is voluntary.
• You can limit the communications that GoJolly sends to you.
  • To opt-out of marketing emails, simply click the “unsubscribe” link at the bottom of any marketing email we send you or by changing the relevant settings in your account.
  • You can always update your notification settings within your GoJolly Account by changing the relevant account settings. Please note that even if you opt-out of marketing communications, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations or fraud alerts.

4. SHARING & DISCLOSURE

4.1 Advertising and Social Media; Sharing With Your Consent.

Where you have provided consent, we may share your information (including personal information) with partners and third parties, such as when you authorize a third-party application or website to access your User Account or when you participate in promotional activities conducted by GoJolly partners or third parties.

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

The third-party social media platforms with which we may share your personal information are not controlled or supervised by GoJolly. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such third-party provider.

Please note that you may, at any time ask GoJolly to cease processing your data for these direct marketing purposes by sending an e-mail support@gojolly.io.

4.2 Sharing between Users.

To help facilitate bookings or other interactions between Users, we may need to share certain information, including personal information, with other Users, as it is necessary for the adequate performance of the contract between you and us, as follows:

• When you as an Explorer submit a booking request, certain information about you is shared with the Host(s), including your profile, full name, the full name of any additional Explorers, your cancellation history, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the Experience, like your phone number.
• When you as a Host have a confirmed booking, certain information is shared with the Explorer (and the additional Explorers they may invite or give a gift, if applicable) to coordinate the booking, such as your profile, full name, phone number, Experience Venue address and location.
• When you as a Explorer give a gift or invite additional Explorers to a booking, your full name, travel dates, Host name, Invitation details, the Experience Venue address, and other related information will be shared with each additional Explorer.

4.3 Profiles, Invitations, and other Public Information.

The Platform lets you publish information, including personal information, that is visible to the general public. For example:

• Parts of your public profile page, such as your first name, your photograph and description, and city, are publicly visible to others.
• Invitation pages are publicly visible and include information such as the Experience’s approximate location (neighbourhood and city) or precise location (where you have provided your consent), Invitation description, calendar availability, your public profile photo, aggregated demand information (like page views over a period of time), and any additional information you choose to share.
• Gift Pages are visible to Sender, Receiver, Host and GoJolly and include information such as the Experience’s approximate location (neighbourhood and city) or precise location (where you have provided your consent), Invitation description, calendar availability, your public profile photo, aggregated demand information (like page views over a period of time), and any additional information you choose to share.
• After completing a booking, Explorers and Hosts may write Reviews and rate each other. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on the Platform (such as the Invitation page).
• If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Platform, that content is publicly visible.

Based on our legitimate interest to promote the Platform we may display parts of the Platform (e.g., your Invitation page or gift page) on sites operated by GoJolly’s business partners, using technologies such as widgets or APIs. If your Invitations are displayed on a partner’s site, information from your public profile page may also be displayed.

If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third-party search engines, and they may use caches containing your outdated information.

4.4 Additional Services by Hosts.

Hosts may need to use third party services available through the Platform to assist with managing their Experience or providing additional services requested by you, such as concierge, transport. Hosts may use features on the Platform to share information about the Explorer (like check-in and check-out dates, Explorer name, Explorer phone number) with such third-party service providers for the purposes of coordinating the Experience, managing the Experience Venue, or providing other services. Hosts are responsible for third party service providers they use and ensuring those service providers process Explorer information securely and in compliance with applicable law including data privacy and data protection laws.

4.5 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

We may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary to:

comply with our legal obligations,

comply with a valid legal request or to respond to claims asserted against GoJolly,

respond to a valid legal request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability,

enforce and administer our Terms of Service, the payment terms or other agreements with Users, or

protect the rights, property or personal safety of GoJolly, its employees, its Users, or the public. For example, if permitted due to the forgoing circumstances, Host information may be shared with tax authorities or other governmental agencies.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

Where appropriate, we may notify Users about legal requests unless: (i) providing notice is prohibited by the relevant legal process, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon GoJolly’s property, its Users and the Platform. In instances where we comply with legal requests without notice for these reasons, we may attempt to notify that User about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

4.6 Service Providers.

We use a variety of third-party service providers to help us provide services related to the Platform and the Payment Services. Service providers may be located inside or outside of the United Arab Emirates. In particular, our service providers are based in Europe, Asia Pacific and North and South America.

For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the GoJolly Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims. These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions to perform the services associated with the Platform.

We will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

4.7 Corporate Affiliates.

To enable or support us in providing the Platform and the Payment Services, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.

• Sharing with GoJolly affiliates. Your information may be shared with GoJolly affiliates that provide the technical infrastructure for the Platform, product development and maintenance, customer support, trust and safety and other business operation services to other GoJolly entities. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the services through the Platform.
• Sharing with third party payments processors. In order to facilitate payments on or through the Platform, certain information as described above in “Information that is necessary for the use of the Payment Services” section above, may be shared with the respective third-party payment processor (Stripe or such other third party whom may from time to time provide the relevant services). The data sharing is necessary for the performance of the contract between you and us.

Additionally, we share your information, including personal information, with our corporate affiliates in order to support and integrate, promote, and to improve the Platform and our affiliates’ services.

4.8 Collection and Remittance of Taxes.

In jurisdictions where GoJolly facilitates the collection and remittance Taxes (as described in the “Taxes” section of the Terms of Service), Hosts and Explorers, where legally permissible according to applicable law, expressly grant us permission, without further notice, to disclose Hosts’ and Explorers’ data and other information relating to them or to their transactions, bookings and Invitations to the relevant tax authority, including, but not limited to, the Host’s or Explorer’s name, Experience Venue addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Hosts from Explorers, and contact information.

4.9 Government Registration.

In jurisdictions where GoJolly facilitates or requires a registration, notification, permit, or license application of a Host with a local governmental authority through the Platform in accordance with local law, we may share information of participating Hosts with the relevant authority, both during the application process and, if applicable, periodically thereafter, such as the Host’s full name and contact details, Experience Venue address, tax identification number, Invitation details, and other relevant information.

4.10 Information Provided to Enterprise Customers.

If you have linked your User Account to the User Account of a company or other organization (an “Enterprise”), added your work email address, or have a booking facilitated via another party (such as the future employer or other entity) or used a coupon in a similar capacity in connection with an Enterprise, that Enterprise will have access to your name, contact details, Explorer information, permissions and roles, and other information as required to enable use by you and the Enterprise

4.11 Business Transfers.

If GoJolly undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4.12 Aggregated Data.

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

5. OTHER IMPORTANT INFORMATION

5.1 Analysing your Communications.

We may review, scan, or analyse your communications on the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our safety and fraud prevention efforts, we may scan and analyse messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyse messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyse your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

These activities are carried out based on GoJolly's legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

5.2 Linking Third Party Accounts.

You may link your User Account with your account at a third-party social networking service. Your contacts on these third-party services are referred to as “Friends.” When you create this link:

• some of the information you provide to us from the linking of your accounts may be published on your User Account profile;
• your activities on the Platform may be displayed to your Friends on the Platform and/or that third party site;
• a link to your public profile on that third party social networking service may be included in your GoJolly public profile;
• other GoJolly users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
• other GoJolly users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service;
• the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
• the publication and display of information that you provide to GoJolly through this linkage is subject to your settings and authorizations on the Platform and the third-party site.

We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.

5.3 Third Party Partners & Integrations

The Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). GoJolly doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, GoJolly, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

Parts of the Platform may use third party services such as Google Maps/Earth services, including the Google Maps API(s), and Stripe. Use of these respective services is subject to their respective privacy policies such as Google Maps/Earth Additional Terms of Use, and the Google Privacy Policy.

6. YOUR RIGHTS

Consistent with applicable law, you may exercise any of the rights described in this section before your applicable GoJolly Data Controller and Payments Data Controller. You may contact us at support@gojolly.io to submit a data rights request. Please note that we may ask you to verify your identity and request before taking further action on your request and may charge an administrative fee to assist in such requests.

6.1 Managing Your Information.

You may access and update some of your information through your Account Details. If you have chosen to connect your User Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app through the respective third-party application. You are responsible for keeping your personal information up-to-date.

6.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your User Account).

6.3 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format.

6.4 Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information:

• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a User Account for fraud or safety reasons, we may retain certain information from that User Account to prevent that User from opening a new User Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Platform, even after your User Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
• Because we maintain the Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period.

6.5 Withdrawing Consent and Restriction of Processing.

If we are processing your personal information based on your consent you may withdraw your consent at any time by emailing us at support@gojolly.io specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of GoJolly override your own.

6.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask GoJolly to cease processing your data for these direct marketing purposes by sending an e-mail to support@gojolly.io.

6.7 Automated decision making and profiling

You have the right not to be subject to a decision by us based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you unless you have given your explicit consent or unless otherwise permitted under the applicable law.

6.7 Lodging Complaints.

You have the right to lodge complaints about our data processing activities by filing a complaint with at support@gojolly.io.

7. OPERATING GLOBALLY & INTERNATIONAL TRANSFERS

To facilitate our global operations GoJolly may transfer, store, and process your information within our family of companies, partners, and service providers based in beyond the UAE and the GCC. Laws in these countries may differ from the laws applicable to your country of residence. For example, information collected within the GCC may be transferred, stored, and processed outside of the GCC for the purposes and on the legal bases described in this Privacy Policy. Where we transfer store and process your personal information outside of the GCC. We have ensured that appropriate safeguards are in place to ensure an adequate level of data protection. You can request further detail about the safeguards that we have in place in respect of transfers of your personal information outside of the GCC and where applicable a copy of the standard data protection clauses that we have in place, by contacting us at support@gojolly.io.

8. SECURITY

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your User Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your User Account, please contact us immediately following the instructions in the Contact Us section.

9. CHANGES TO THIS PRIVACY POLICY

GoJolly reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least fourteen (14) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your User Account. If you do not cancel your User Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Platform will be subject to the revised Privacy Policy.

10. CONTACT US

If you have any questions or complaints about this Privacy Policy or GoJolly’s information handling practices, you may email us at the email addresses provided in the relevant sections above or contact us via mail at:

GoJolly Data Controller: support@gojolly.io