PRIVACY POLICY FOR THE MOBILE APPLICATION "AIVI ASSISTANT"

This Privacy Policy applies to all information that the mobile application, available on the Google Play platform, may collect about the User during the use of the application.

1. Key Terms

1.1. Policy – this Privacy Policy of the mobile application AIVI ASSISTANT.”

1.2. User – any individual using the Mobile Application in accordance with the applicable laws of the United Arab Emirates, the terms of the User Agreement, and this Policy.

1.3. Rights Holder – ZPOOL FZCO (King Salman Bin Abdulaziz Al Saud Street, near Tram Station and Cordoba Residence - Dubai, UAE), which holds the exclusive rights to the Mobile Application.

1.4. Mobile Application (hereinafter referred to as the "Application") – software developed for the Android mobile platform, designed for installation and use on smartphones, providing access to its functionality.

1.5. Processing of Personal Data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

1.6. Confidentiality of Personal Data – a mandatory requirement for the Operator or any person who has gained access to personal data to prevent their disclosure without the consent of the data subject or a legal basis.

1.7. User of the Mobile Application (hereinafter referred to as the "User") – an individual who has access to the Mobile Application via the Internet and uses the application.

1.8. User's Personal Information – personal information that the User provides about themselves independently during registration (account creation) or while using the Application, including the User’s personal data. This also includes data automatically transmitted to the Rights Holder during the use of the Application installed on the User’s Device, including information about the User’s Device.

1.9. Device – a mobile technical device (smartphone, tablet, or other device) that has Internet access and on which the Application is installed.

2. General Provisions

2.1. This Policy applies to all information that the Rights Holder may obtain from the User’s Device during the use of the Mobile Application.

2.2. Use of the Application constitutes the User’s unconditional acceptance of this Policy and the terms of data processing specified herein. If the User does not agree with this Policy, they must refrain from using the Mobile Application.

2.3. The Rights Holder does not control and is not responsible for the content, policies, or practices of any third-party websites or services that the User may access via links available in the Application. Such websites may collect or request other personal information from the User and perform additional actions.

2.4. This Policy applies solely to the Mobile Application. The Rights Holder does not control and is not responsible for information (or any consequences of its transfer) that the User provides to a third party when accessing third-party resources via links from the Application.

2.5. The Rights Holder does not verify the accuracy of personal information provided by Users and does not monitor their legal capacity.

2.6. The Rights Holder assumes that the information provided by Users is accurate and keeps this information up to date.

2.7. By installing the Application on their mobile device, the User, within the purposes specified in this Policy, grants the Rights Holder consent to collect, process, record, systematize, store, modify, anonymize, delete, alter, and use the User’s personal data for the purpose of providing the Rights Holder’s services.

3. List of Collected Personal Data

3.1. While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You.

Personally identifiable information may include, but is not limited to:

• Full name, phone number, email address;
• IP address, device type, operating system. This information is used to detect and resolve technical issues and to monitor the legality of financial transactions;
• Contacts – a list of contacts provided by the User through messengers or email services connected to the application for integration purposes;
• Financial data – if required for processing payments;
• Activity data within the application – for analytics and improving the application's functionality.

3.2. While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Information from your Device's phone book (contacts list)

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device. You can enable or disable access to this information at any time, through Your Device settings.

3.3. The Application does not collect biometric data, payment card details, or User passwords.

3.4. Any other personal information not specified above is securely stored and not disclosed, except in cases provided for in Sections 5.2 and 5.3 of this Privacy Policy.

4. Purposes of Collecting and Processing Personal Data

4.1. The processing of the User’s personal data is carried out in accordance with the laws of the United Arab Emirates. The Rights Holder processes the User’s personal data for the following purposes:

• Identifying the User to provide access to services;
• Communicating with the User;
• Improving the application's performance and personalizing content;
• Analyzing application usage for statistical purposes;
• Preventing fraud and ensuring security;
• Sending notifications and news with the User’s consent.

4.2. The Rights Holder may use the User’s personal data for the following purposes:

4.2.1. Identifying the registered User in the application for order processing.

4.2.2. Establishing communication with the User, including sending notifications and requests related to application usage, service provision, and processing of inquiries and requests from the User.

4.2.3. Determining the User’s location to ensure security and prevent fraud.

4.2.4. Processing and receiving User payments.

4.2.5. Providing effective customer and technical support to the User in case of issues related to application usage.

4.2.6. Providing the User, with their consent, updates on products, special offers, pricing information, newsletters, and other application-related information.

4.2.7. Conducting advertising activities with the User’s consent.

5. Conditions for Processing and Transferring User’s Personal Information to Third Parties

5.1. The Rights Holder takes all necessary measures to protect the User’s personal data from unauthorized access, modification, disclosure, or destruction.

5.2. The Rights Holder grants access to the User’s personal data only to employees, contractors, and affiliated parties who require this information to ensure the operation of the application, services, and the provision of goods, services, or a non-exclusive license to the User.

5.3. The Rights Holder has the right to use the information provided by the User, including personal data, to comply with the laws of the United Arab Emirates (including for the prevention and/or suppression of illegal and/or unlawful actions by Users). Disclosure of the information provided by the User may only be carried out in accordance with the applicable laws of the United Arab Emirates at the request of a court, law enforcement authorities, or in other cases provided for by the laws of the United Arab Emirates.

5.4. The Rights Holder does not verify the accuracy of the information provided by the User and assumes that the User provides accurate and sufficient information in good faith and ensures the timely updating of previously provided information when necessary.

5.5. The Rights Holder employs modern data protection measures, including but not limited to:

• Using HTTPS for all communication;
• Storing OAuth tokens and sensitive data in encrypted storage;
• Implementing user authentication and server protection against unauthorized access;
• Allowing Users to revoke access and delete their data at any time.

5.6. In the event of a data breach, the Rights Holder undertakes to notify the User and the competent authorities.

5.7. Terms of Using the Mobile Application

5.7.1. By using the Mobile Application, the User confirms that they:

• Have all the necessary rights to register (create an account) and use the application;
• Provide accurate information about themselves to the extent necessary for using the Mobile Application, while any additional information is provided at their discretion;
• Understand that any information posted by the User on third-party resources through the application may become accessible to third parties not specified in this Policy and may be used by them beyond the Rights Holder’s control;
• Have read this Policy, agree to its terms, and accept the obligations set forth herein. Reading the terms of this Policy, installing, and registering in the application constitute the User’s consent (acceptance) to the collection, storage, processing, and transfer of personal data to third parties as provided by the User.

5.8. The Rights Holder does not verify the accuracy of the information received (collected) about Users, except in cases where such verification is necessary to fulfill obligations to the User.

5.9. The User’s personal data is stored until the account is deleted or for one (1) calendar year after the last use of the application.

5.10. Google User Data

The Application may access Google user data (for example, through the Google Calendar API) strictly for the purpose of providing the requested functionality within the Application.

• We do not share, transfer, or disclose Google user data to any third parties, except as required by law.
• All Google user data accessed through the Google APIs is used solely within the Application to provide services requested by the User.
• We do not sell or use Google user data for advertising or marketing purposes.

6. Retention of Personal Data

6.1. The Right Holder will retain the User’s Personal Data only for as long as necessary for the purposes set out in this Privacy Policy. The Right Holder will retain and use the User’s Personal Data to the extent necessary to comply with its legal obligations (for example, if the Right Holder is required to retain data to comply with applicable laws), resolve disputes, and enforce its legal agreements and policies.

6.2. The Right Holder will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen security, improve the functionality of the Service, or if the Right Holder is legally obligated to retain this data for longer periods.

7. Transfer of Personal Data

7.1. The User’s information, including Personal Data, is processed at the Right Holder’s operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to and maintained on computers located outside the User’s state, province, country, or other governmental jurisdiction where data protection laws may differ from those in the User’s jurisdiction.

7.2. The User’s consent to this Privacy Policy, followed by the submission of such information, represents their agreement to that transfer.

7.3. The Right Holder will take all steps reasonably necessary to ensure that the User’s data is treated securely and in accordance with this Privacy Policy, and no transfer of Personal Data will take place to an organization or a country unless adequate controls are in place, including the security of the User’s data and other personal information.

8. Modification and Deletion of Personal Data

8.1. The User may modify (update, supplement) the personal information they have provided, either partially or entirely, as well as adjust its privacy settings at any time. This can be done using the personal data editing feature within the relevant service section or by sending a request to the Rights Holder.

8.2. The User is responsible for keeping their previously provided information up to date. The Rights Holder is not liable for any issues arising from outdated information.

8.3. The User also has the right to delete the personal information associated with their account.

8.4. For inquiries regarding personal data processing, the User may contact the Rights Holder at request@z-pool.com.

9. Obligations of the Parties

9.1. The User has the right to:

• Access the list of collected personal data;
• Request correction or deletion of data;
• Restrict the processing of their data;
• Withdraw consent for personal data processing;
• File a complaint with data protection authorities.

For data protection inquiries, the User may contact request@z-pool.com.

9.2. The User is obliged to:

9.2.1. Provide the personal data necessary for using the mobile application.
9.2.2. Update and supplement the provided personal data in case of any changes.

9.3. The Rights Holder is obliged to:

9.3.1. Use the collected information solely for the purposes outlined in Clause 4.2 of this Privacy Policy.
9.3.2. Maintain the confidentiality of the User’s information, not disclose it without prior written consent from the User, and not sell, exchange, publish, or disclose the User’s personal data in any other way, except as provided in Clauses 5.2 and 5.3 of this Privacy Policy.
9.3.3. Take precautionary measures to protect the confidentiality of the User’s personal data according to standard business practices for protecting such information.
9.3.4. Block personal data related to the respective User upon request from the User, their legal representative, or an authorized data protection authority for the duration of an investigation in cases of inaccurate personal data or unlawful actions.

10. Liability of the Parties

10.1. The Rights Holder is responsible for the unlawful use of personal data within the limits established by the laws of the United Arab Emirates, except in cases specified in Clauses 5.2, 5.3, and 7.2 of this Privacy Policy.

10.2. In the event of loss or disclosure of Confidential Information, the Rights Holder shall not be held liable if the Confidential Information:
10.2.1. Became publicly available before its loss or disclosure.
10.2.2. Was obtained from a third party before it was received by the Rights Holder.
10.2.3. Was disclosed with the User’s consent.

11. Dispute Resolution

11.1. Before filing a lawsuit regarding disputes arising from the relationship between the User and the Rights Holder, it is mandatory to submit a claim (a written proposal for voluntary dispute resolution).

11.2. The recipient of the claim must provide a written response regarding the results of the claim review within 30 calendar days from the date of receipt.

11.3. If no agreement is reached, the dispute shall be referred to a judicial authority in accordance with the applicable laws of the United Arab Emirates.

11.4. This Privacy Policy and the relationship between the User and the Rights Holder shall be governed by the applicable laws of the United Arab Emirates.

12. Changes to the Privacy Policy and Applicable Law

12.1. The Rights Holder reserves the right to make changes to this Privacy Policy. The latest version will indicate the date of the most recent update.

12.2. If the Privacy Policy is updated, the Rights Holder will notify the User via push notifications in the app or by email, provided that the User has consented to receive such notifications.

12.3. The new version of the Privacy Policy takes effect from the moment it is published unless otherwise specified in the updated version.

12.4. This Privacy Policy and any relationships between the User and the Rights Holder arising from its application shall be governed by the laws of the United Arab Emirates.

12.5. It is the User’s responsibility to stay informed about the latest version of this Privacy Policy.

12.6. Continuing to use the app after changes have been made implies acceptance of the updated Privacy Policy.

If you have any questions about this Privacy Policy, You can contact us:

ZPOOL FZCO
Address: King Salman Bin Abdulaziz Al Saud Street,

near Tram Station and Cordoba Residence - Dubai, UAE
Email: request@z-pool.com