CONFIDENTIALITY, PERSONAL DATA PROCESSING (PRIVACY) AND COOKIE POLICY

1. ABOUT US. We are the GSR System FZ CO company, we process your personal data, acting as a Personal Data Controller. This means that we are responsible for the processing and protection of your data.

2. WHAT WE USE YOUR DATA FOR.
We use your data (obtained online or in person), among other things, to manage your user registration, to administer your purchases of services, to respond to your inquiries, and, if you wish, to send you personalized communications.

3. REASON TO USE YOUR PERSONAL DATA.
We have legitimate grounds for processing your personal data for several reasons. The main reason is that the processing of your personal data is a necessary condition for the performance of the contract you enter into with us when you register, as well as when you make a purchase or use any of our services. We also use your information for other purposes, such as responding to your inquiries and sending you newsletters that you have subscribed to.

4. WHOM WE GIVE ACCESS TO YOUR PERSONAL DATA.
We only share your data with service providers who assist or support us, only as required by law.

5. YOUR RIGHTS.
You have the right to access, correct or delete your personal data. In some cases, you may also exercise other rights, such as the right to object to the use or transfer of your data, as detailed below.
We encourage you to read our entire Privacy Policy below for a complete understanding of how we will use your personal information and your rights in relation to your personal information.

BEFORE WE START…

• In this Privacy and Cookie Policy, you will find all the necessary information regarding our use of the personal data of our users and customers, regardless of the channel or means of transmission (online or in person) that you use to interact with us.
• We are transparent in all transactions with your personal data so that you fully understand how and why we use your data, and what rights you have in relation to your data:
• We provide you with permanent access to the Privacy and Cookie Policy and all information provided therein. You can review it at any time.
• You can also learn more about how we use your data by continuing to interact with us.
• The following are a number of terms that are regularly referred to in this Privacy & Cookie Policy.
• "Platform" generally refers to any channels or means that you use to interact with us (either digitally or in person). The main one is the following:
• Our Website https://gsrsystem.org/

1. WHO IS OPERATOR OF YOUR DATA?
Operator of data:

▪ Company GSR SYSTEM FZ CO

o DSO-IFZA-10697, Dubai Digital Park, Office A2, Dubai Silicon Oasis, Dubai, United Arab Emirates

2. WHY DO WE USE YOUR PERSONAL DATA
Depending on the purposes for which we process some of your personal data from time to time, as set out below, we need to process, on a case-by-case basis, the following types of data:

▪ information that proves your identity (for example, your first name, last name, photo, language, country where you are located, contact details, etc.);
▪ economic and transactional data (for example, payment and bank card data, information about purchases, orders, returns, etc.);
▪ connection data, geographic location and/or browser data (for example, location data, device ID, advertiser ID, etc.); ▪ commercial information (if you subscribe to our newsletter, etc.);
▪ information about your tastes and preferences.

Please remember that whenever you are required to provide your personal data in order to access any feature or service of the Platform, certain fields will be marked as required fields: we need this information in order to provide you with the requested service or to provide access to certain options. and functions. Please note that if you choose not to share this information with us, you may be denied registration or use of these services or options.
In certain cases, a third party may have provided us with information about you by using a feature or service on the Platform, such as sending you a gift card or sending an order to your address. In these cases, we process your data only to the extent that it is relevant to such feature or service, as set out in this Privacy Policy and the Cookie Policy.
In other cases, we may collect information passively through the use of tracking tools such as browser cookies and other similar technologies on our Platform and in communications sent to you.
Depending on how you interact with the Platform, i.e. what services or options you are interested in, we process your personal data for the following purposes:

PURPOSE

DETAILS

1. Management of your registration entry on our Platform

If you choose to become a registered user of our Platform, we need to process your data in order to identify you as a user of the Platform and to provide you with access to its features, products and services (as a registered user). You can delete your registered user account by contacting our customer service department.
We hereby inform you that the data about your activities that we collect through other channels of the Platform and which includes information about your purchases will be associated with your account, so that aggregated information can be accessed.

2. Analysis of customers experience
When you access our Platform, we inform you that we will process your browsing data for analytical and statistical purposes, in particular to understand how users interact with our Platform, in order to improve our services.
In addition, we periodically conduct quality surveys and take the necessary measures to determine the degree of satisfaction of our customers and users and identify areas and areas for improvement.

3. To sign and fulfill contracts concerning services on our Platform

This includes the processing of your personal data mainly for the following purposes:
▪ To send you updates and notifications regarding the features and services that are the subject of the contract, including quality surveys, in order to determine the degree of customer satisfaction with the services provided.
▪ To administer payment for the services you purchase, regardless of the payment method you choose. Example:
▪ When you purchase any of our products on our website or app, if you choose to enable the option to save your payment information for future purchases (where available), we need to process that information in order to enable this feature. If you agree to activate this option (autocomplete option), your payment details will automatically appear in the appropriate fields for future purchases. You can change your payment details or delete them at any time.
▪ To activate the mechanisms necessary to prevent and detect cases of unauthorized use of the Platform, as well as possible fraudulent activities committed against you and/or against us. If we believe that a transaction may be fraudulent, or detect unusual behavior that indicates an attempted fraudulent use of our features or services, such processing may result in the transaction being blocked or your user account being terminated.
▪ To process the management of requests for availability of services and their booking through the Platform, depending on the availability of these options at any given time.
▪ For the purposes of billing and providing checks and invoices for purchases made through the Platform;

4. For answers on your requests in the customer care process

We process only those personal data that are strictly necessary to process your applications or to answer the questions set out in them.
If you contact us by telephone, the call may be recorded for quality assurance purposes and to enable us to respond to your request.
If you select chat on social networks and other resellers (if available) as your customer service channel, some of your personal data, such as your name or username, will be imported from the social network or account with the reseller. Also, remember that the data you submit to this service will be available to your social network or reseller and subject to their privacy policies, so we recommend that you check your privacy settings and read the social network or reseller's privacy policies to learn more. detailed information about how they use the personal data of users of their services.

5. For marketing purposes

This includes the processing of your personal data for the following purposes:
To show you advertisements on the Internet that you may see when you visit websites and applications, such as social networks. The advertisements you see may be random, but in some cases they may be related to your preferences or your browsing history and purchases.
To personalize the services we offer you and to enable us to provide you with better offers.

3. LEGAL GROUNDS TO PROCESS YOUR PERSONAL DATA
The legal grounds that give us the right to process your personal data depend, among other things, on the purposes for which we process it, as set out in the table below:

PURPOSE

Legal grounds

1. Management of your registration entry on the Platform

We process your data because it is necessary in accordance with the terms and conditions governing the use of the Platform. In other words, in order for you to register on the Platform as a user, we need to process your personal data. Otherwise, we will not be able to manage your registration.
We have a legitimate interest in associating purchase information and activity data collected through various channels of the Platform with your account.

2. Drafting and fulfilling of contracts to sell services

We process your data because it is necessary to enter into a service contract with you.
Certain processing of data related to the purchase process is only enabled when you request or authorize it, such as when storing payment data for future purchases or enabling "Coming soon" or "Back in stock" alert options (if available) such functions). In these cases, the processing of your data is based on your consent. In addition, we process your location data when you give us consent to offer you specific services through the app when you visit some of our stores.
We believe that we have the legal right to carry out the necessary verification procedures when making a purchase or return in order to identify and prevent potential abuse or fraud when using the Platform. We understand that the processing of such data is in the interests of all parties involved: for you, insofar as it allows us to take steps to protect you from fraud attempts by third parties, and for us, insofar as it allows us to prevent unauthorized use of the Platform; for all of our customers and society as a whole, as this protects their interests by preventing fraud and detecting it when it does occur

3. Customer care

We believe that we have the legal right to respond to any of your inquiries through the various channels of communication available. We understand that the processing of such data is also in your interests, to the extent that it allows us to provide you with appropriate support and answer your questions.
In particular, the processing of your data is necessary for the performance of a service agreement when contacting us to resolve unforeseen situations related to your order or product/service purchased through the Platform. If your request is related to the exercise of your rights, which we inform you about below, or claims in relation to our products or services, then we have a legal right to process your data in order to comply with our legal obligations.

4. Marketing

We have the legal right to process your data for marketing purposes based on the consent you give us, for example, by agreeing to receive personalized information through various channels, by agreeing to receive push notifications on your mobile device, by setting appropriate privacy settings on your mobile device, by agreeing to cookie settings.
We believe we have a legitimate interest in profiling based on the information we hold about you (including your browsing history, preferences or purchase history) and the personal information you have provided to us, including but not limited to about your age group or language – for the purposes of providing you with personalized services or displaying personalized information on our Platform or on third party platforms, or for data enrichment purposes – as we understand that such data is also processed in your interests, as this allows you to improve your user experience and access information according to your preferences.

5. Analysis of customers experience

Based on our legitimate interest, we perform an analysis of user experience and user satisfaction with the Platform. The processing of this data is also carried out in your interests, since its purpose is to improve your user experience and provide you with better services.

4. HOW LONG DO WE STORE YOUR PERSONAL DATA?

The retention period for your personal data depends on the purposes for which it is processed, as set out below:

PURPOSE

Term to store personal data

1. Management of your registration entry on the Platform

Your data is processed for as long as you remain a registered user (that is, until you decide to unsubscribe).

2. Drafting and fulfilling of contracts to sell services

We process your data for the period necessary to provide the services, as well as complaints or claims related to the purchase of said services.

3. Customer care

We process your personal data for the period necessary to respond to your request.

4. Marketing

We process your personal data until you unsubscribe from the newsletter.

Similarly, we will show you ads tailored to your individual interests until you change your device, browser or cookie settings to revoke the permission.

5. Analysis of customers experience

We process your data on an as-needed basis for as long as we need to perform a quality assurance procedure or study, or until we anonymize your browsing data.

Although we process your data strictly for the period necessary to achieve the required purpose, we further ensure that they are properly stored and protected for the period during which liability may arise in connection with their processing in accordance with applicable law. We delete your personal data after the statute of limitations for potential liability.

5. DO WE TRANSFER YOUR DATA TO THIRD PARTIES

To achieve the purposes set out in this Privacy and Cookie Policy, we must also ensure that third parties that support us in providing services to you have access to your personal data, including:

▪ financial institutions;

▪ institutions and services involved in the detection and prevention of fraud;

▪ technology and analytical service providers;

▪ service providers and partners related to logistics, transport and delivery, and (or) their partner organizations;

▪ companies providing services related to customer service;

▪ service providers and partners related to marketing and advertising, such as social media websites, advertising agencies and advertising partners.

6. WHICH RIGHTS DO YOU HAVE PROVIDING US WITH YOUR PERSONAL DATA
We are committed to ensuring the confidentiality of your personal data, as well as the necessary conditions for the exercise of your rights. You can exercise your rights free of charge by sending a letter to the legal address above, stating the reason for your application and the right you wish to exercise. If necessary, we may ask you to provide us with a copy of your identity document.
In addition, we may offer you the ability to exercise your rights and set your privacy preferences when using some of our services or through the provision of certain channels within our Platform.
In particular, regardless of the purpose and legal basis for the processing of your data, you have the following rights:
• Request access to personal data we hold. We remind you that if you are a registered user of the Platform, you can view this information in the relevant section of your account.
• Request corrections and changes to the personal data we hold. Please note that if you are a registered user of the Platform, then you can change or update your personal data in the appropriate section of your account on the Platform. Please note that by granting us access to your personal data by any means, you undertake to guarantee its accuracy and reliability, as well as to notify us of any changes. You are responsible for any damage caused to the Platform or the person in charge of the Platform, or any third party, if you provide us with erroneous, inaccurate or incomplete information when registering. Please note that you are generally only required to provide us with your personal data and not third party data, unless the Privacy and Cookies Policy provides otherwise.

• Request deletion of your personal data where it is no longer required for the purposes for which we needed to process it as set out above, or where we no longer have legal grounds for processing it.

• Request deletion or restriction of processing of your personal data. This means that in certain cases you can request that the processing of your data be suspended or stored for a longer period than necessary.
If you have given us your permission to process your data for any purpose, you also have the right to revoke that permission at any time. Some of the circumstances under which you may withdraw your consent are set out in section 2, which sets out the purposes of processing your personal data.
If you do not want us to send information to third parties to serve ads to you, there are several ways you can opt out, such as by changing the settings on your device, by changing your browser and/or cookie settings, and by reviewing the privacy policy and checking your settings. on social networking sites where you have profiles, or by sending us an email at the above email address with information about your request.
Where we have a legal right to process your personal data based on your consent or for the purposes of a contract as set out in section 3, you also have the right to request the transfer of your personal data. This means that you will have the right to receive the personal data provided to us in a structured, universal and machine-readable format, as well as to transfer it directly to other institutions, without any obstacles on our part.
In addition, where the processing of your data is based on our legitimate interests, you also have the right to object to the processing of your personal data.

7. CHANGES IN THE PRIVACY AND COOKIE POLICY
We may change the content of this Privacy and Cookie Policy at our sole discretion. In this case, we will notify you of these changes using certain functions of the Platform (for example, a banner, pop-up notification or push notification). In addition, we may send a notification to your email address in cases where changes are made in one way or another to protect your privacy, so that you can review the changes and, if you wish, opt out or unsubscribe from any service or option. We recommend that you periodically review the Privacy and Cookie Policy for possible changes, as well as online changes and improvements. This document is freely available on our Website at all times.

8. INFORMATION ON COOKIE FILES
We use cookies and other similar tools to improve your experience on our Platform, to learn about user interactions with the Platform and, in certain cases, to be able to show you ads based on your previous browsing experience. Please read the information about cookies to get a better idea about them and other tools we use, their purpose, how to manage your preferences, and other information that may be of interest to you.

POLICY ON COOKIE FILES

BEFORE WE START…

This cookie policy provides information on the use of cookies and similar devices installed on the terminals of our customers and users. In some cases, cookies may be associated with the processing of personal data, and therefore we recommend that you read the "Privacy Policy" document available on our Platform if you want to know how we process the personal data of our customers and users, how to use our rights or what terminology we use in relation to our Platform (website, application or physical stores).

INFORMATION ON COOKIE FILES

What is a cookie?

A cookie is a small text file, similar to a label, to identify your device. It is installed by a website, application or other platform on your computer, tablet, smartphone or any other similar device and contains information about your navigation or activities. Cookies are necessary, for example, to provide better navigation and to track user interactions with platforms in order to implement improvements. They also serve the purpose of tailoring the display of advertisements to the user's preferences and for the other purposes described below. Cookies do not cause any harm to a computer or other device.
By the term "cookies" we also mean other similar technologies for setting and/or collecting information about your device (such as flash cookies, web beacons or bugs, pixels, HTML5 (for local storage) and SDK technologies for applications. Also, the term " "cookies" refers to the use of fingerprinting technology, i.e. methods of combining data to identify your device. In some cases, these technologies are used in conjunction with cookies to collect and store information in order to provide certain features and services on our Platform or to show you advertisements on third party platforms based on your navigation.
This general information about what cookies are is for informational purposes only. For more information about which cookies we use, please visit the cookie settings panel on our Platform.

What types of cookies are there?

Please read this section to get an overview of the types of cookies used on the web.
Depending on the owner, cookies can be classified as follows:
a. Own cookies. These are the files that are sent to the user's computer or device from a computer or domain managed by the publisher itself, and from which the platform or service requested by the user is operated.
b. Third Party Cookies. These cookies are sent to the user's computer or device from a computer or domain that is not managed by the publisher itself, but by another organization that processes the data obtained through cookies.

Depending on the purpose, cookies can be classified as follows:

a. Mandatory (technical) cookies. These files allow the user to navigate within a website, platform or application and use the various options or services available therein. Such as controlling traffic, identifying data or session, viewing sections or content with restricted access, remembering items in an order, completing a purchase, making a payment, controlling the security of the service and possible cases of fraud, using security elements during navigation, requesting registration or participation in a promotion, storing data for posting video or sound files, activating dynamic content (such as animations when text or images load), or posting content on social networks. Technical cookies are mandatory and are therefore downloaded by default in order to guarantee access to the platform or the provision of a service to the user.
b. Functional or personalization cookies. These cookies allow information to be stored in order for the user to access a platform or service with certain characteristics that distinguish their session from those of other users. This may be, for example, the language, the number of search results per page, the appearance or content of the service depending on the type of browser used or the region from which the service is accessed, and so on. Failure to use these cookies may result in slow website performance or non-compliance with recommendations.
c. Analytical cookies. These files allow you to control the number of users, visits to sections of the platform and interaction with it, as well as measure and perform statistical analysis of user behavior in order to implement improvements based on the analysis of data on user interaction with the platform or service.
d. Advertising cookies based on user behavior. These cookies store information about users' behavior based on continuous tracking of their repeated actions during navigation in order to create a specific profile for displaying advertisements. These cookies allow you to get the most out of the advertising spaces that the publisher uses directly or in collaboration with a third party.

What are cookies used for on our Platform?

Cookies form an integral part of our Platform. Their main goal is to make user navigation as convenient and efficient as possible. For example, they are used to remember your preferences (language, country, etc.) during navigation and for subsequent visits. In addition, we use cookies to continuously improve our services and the Platform, and to display personalized advertisements based on your browsing habits.
We use the information we receive through cookies to improve our Platform based on statistics and usage patterns (number of visits, most visited sections, session time, etc.). In addition, these files allow us to collect statistical data about user interactions with the Platform in order to improve the services and tailor the Platform to your interests, for example, for faster searches, etc.
In some cases, through cookies, we may receive information to display advertisements based on an analysis of your actions while browsing (browsing products, visiting sections, etc.), on our Platform, on third-party platforms or in any other digital spaces.
In any case, our cookies never store personal information such as passwords, credit or debit card details, and so on.

How can you control the use of cookies on this Platform?
In the cookie configuration panel, which is always available on our Platform, you can get all the information about the cookies used on this Platform, as well as learn about the purpose, duration and management (own or third parties) of each of them, in order to control enabling and disabling those cookies that are not strictly necessary for the functioning of the Platform.
In addition, when browsing the Internet, you can disable cookies in your browser. The following is information on how to do this in some of the most common browsers:
• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari
You can use this option to refuse cookies at any time.
Please note that both the options in the cookie configuration panel and the ability to refuse the use of cookies depend on the characteristics of your browser. Thus, if you have configured cookies on one device and want to apply the same settings to another device, you will need to activate the same option on that device.
In addition, with respect to third party cookies required to serve ads tailored to your interests, please note that individual third parties may be part of one of the following programs to automatically adjust ads based on user behavior on the web, with corresponding options for voluntary failure:
• Network Advertising Initiative (NAI) - http://www.networkadvertising.org/choices/
• Google Analytics - https://tools.google.com/dlpage/gaoptout

Who uses the information stored by cookies?

The information stored by cookies on our platform is used only by us, except as referred to in Section 2 as "Third Party Cookies", where cookies are used and managed by third parties who provide digital services to us in order to improve our services and user navigation on our Platform. More information can be found in the cookie configuration panel, which is always available on our Platform.
For more information about the processing of personal data in connection with our cooperation with third parties and international transfers of data, you can refer to the “Privacy Policy” document available on our Platform and the privacy policies or privacy settings of third party platforms.