‍1. Definitions

‍For the purposes of this Privacy Policy:

Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Account means a unique account created for You to access our Service or parts of our Service.

Company (referred to as either “the Company”, “We”, “Us” or “Our”) refers to Spades App FZ-LLC, a company incorporated under the laws of Dubai Development Authority (DDA), bearing registration number 98880 and having its registered office at HD631, First Floor, In5 Tech, Dubai Internet City, Dubai, United Arab Emirates.

Cookies/cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country means United Arab Emirates

Persistent Cookies means those cookies which remain on your personal computer or mobile device when you go offline.

Session Cookies means those cookies which are deleted as soon as you close your web browser.

Service means the Web Application.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate or provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Third-party Social Media Service means any website or any social network website through which a User can log in or create an account to use the Service.

Personal Data means any information that relates to an identified or identifiable individual.

Usage Data means data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

You/you mean the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Website refers to Spades website, accessible from www.spadesapp.io

‍2. Collecting and Using Your Personal Data

‍‍Two basic types of information are collected from you in conjunction with your use of the Our Services (collectively, your “personal information”): (1) personally identifiable information; and (2) non-personally identifiable information. Personally Identifiable Information is any information that can identify you, including but not limited to your name, e-mail address, telephone number, postal address, device identifiers, IP addresses, and financial account information that you provide, such as credit or debit card numbers and bank account number. Personally identifiable information may also be collected by us about you from third parties such as data from Government entities or vendors/merchants. Non-personally identifiable information is information that does not identify you directly but may be linkable to you and includes demographic information and general location information. If non-personally identifiable information is directly linked to personally identifiable information, it will be considered personally identifiable information while it is linked.

‍3. Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

‍4. Tracking Technologies and Cookies

‍We use cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Service. We use both Persistent and Session cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.

5. Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third parties

Purpose: These cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.

6. Targeting and Advertising Cookies

Type: Persistent Cookies

Administered by: Third parties

Purpose: These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.

7. Use of Your Personal Data

‍We may use Personal Data for the following purposes:

– Provide and maintain our Service: to monitor the usage of our Service.

-Manage your account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.

-Performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.

-Contact you: by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

-Provide you: with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

-Manage your requests: To attend and manage your requests to us.

-Process transactions and send notices about your transactions.

-Resolve disputes and collect payments and/or fees.

-Verify the accuracy of and authenticate your information.

-Detect, investigate and prevent potentially prohibited or illegal activities.

-Communicate about accounts or transactions and send information about features and enhancements and communicate changes to our policies.

-Personalize content and experiences, including providing recommendations based on your preferences.

-Provide advertising including advertising based on your use of our Services or third-party websites.

-Perform statistical, demographic and marketing analyses of users of Our Services and their purchasing patterns.

-Conduct any other legitimate business activities not otherwise prohibited by law. We may share your personal information in the following situations:

-With Service Providers: to monitor and analyze the use of our Service, to show advertisements to you to help support and maintain our Service, to contact you, to advertise on third party websites to you after you visited our Service or for payment processing.

-For Business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.

-With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

-With Business partners: We may share your information with our business partners to offer you certain products, services or promotions.

-Third Party Analytics: We may use automated devices and applications to evaluate usage of our Site. We use these tools to help us improve our Site, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services.

-Third parties, including governmental authorities and law enforcement: to (i) protect or defend our legal rights, interests or property and any related entity (ii) protect the safety and security of our customers or members of the public; (iii) protect against fraud; or (iv) comply with applicable law, subpoena or legal process.

-Merchants: You order your goods or services from using Our Services.

-Credit bureaus and collection agencies, as permitted by law.

‍8. Retention of Your Personal Data

‍We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We 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 the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

‍9. Transfer of Your Personal Data

‍Your information, including Personal Data, is processed at Our operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Your Personal Data

-Business Transactions

If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

-Law enforcement

Under certain circumstances, we may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

We may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation;• Protect and defend our rights or property;

• Prevent or investigate possible wrongdoing in connection with the Service;

• Protect the personal safety of Users of the Service or the public;

Protect against legal liability

‍10. Security of Your Personal Data

‍The security of your Personal Data is important to us, but it must be understood and acknowledged by you that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

We use reasonable security measures to protect your personal information from unauthorized access and use in compliance with applicable law. These measures include computer safeguards and encrypted, secured files and buildings. We also maintain other physical, technical, administrative, and procedural safeguards to protect personal information, and access to personal information is limited to the employees who require it for their job functions.

11. Children’s Privacy

‍Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.

‍12. Links to Other Websites

‍Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

‍13. Changes to this Privacy Policy

‍We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14.Resolving your concerns

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

customersupport@spadesapp.io