Owner and Data Controller

The Dream Draw Platform collects Personal Data from its Users.

DREAM DRAW L.L.C.-FZ

U.A.E. Address: Business Center 1, M Floor, Al Meydan Hotel, Meydan Free Zone, Nad Al Sheba, Dubai, United Arab Emirates. Tel: +971 4 397 4070

DPO Contact

U.A.E. Address: Business Center 1, M Floor, Al Meydan Hotel, Meydan Free Zone, Nad Al Sheba, Dubai, United Arab Emirates. Tel: 971 4 397 4070

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This Privacy Policy relates solely to the Dream Draw Platform, if not stated otherwise within this document.

Latest update: 5th September 2021

Definitions and Interpretation

In this Privacy Policy:

• All capitalised words and expressions used shall have the following meanings; and
• Unless the context otherwise requires, words in the singular shall include the plural and, in the plural, shall include the singular.

Types of Data collected

Among the types of Personal Data that this Platform collects, by itself or through third parties, this can be broadly categorised as email address, Usage Data, first name, last name, telephone number, Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and geographic position.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using the Platform. Unless specified otherwise, all Data requested by the Platform is mandatory. Failure to provide this Data may make it impossible for the Platform to provide its Services. In cases where the Platform specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies, or of any other tracking tools, by this Platform or by the owners of third-party services used by this Platform, serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published, or shared through this Platform and confirm that they have the third party's consent to provide the Data to the Owner.

Data Processing

Methods of Processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. Data Processing is carried out using computers and/or IT-enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain persons involved with the operation of the Platform (such as but not limited to: administration, sales, marketing, legal, and system administration) or external parties (such as but not limited to: third party technical service providers, mail carriers, hosting providers, IT companies and communications agencies) appointed, if necessary, as Data Processors by the Owner. An updated list of these parties may be requested from the Owner at any time.

Legal Basis of Data Processing

The Owner may process Personal Data relating to Users if any one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations, the Owner may be allowed to process Personal Data until the User objects to such Data Processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• Processing is necessary for compliance with a legal obligation to which the Owner is subject;
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will help to clarify the specific legal basis that applies to the Data Processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

Data Processing is carried out at the Owner's operating offices and in any other places where the parties involved in the Data Processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can refer to the section “Detailed information on the Processing of Personal Data”.

Users are also entitled to learn about the legal basis of Data transfers to a country outside of the European Union, or to any international organisation governed by public international law or set up by two or more countries (such as the UN), and about the security measures taken by the Owner to safeguard their Personal Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this Privacy Policy or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose/s it has been collected for. Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User and shall be retained until such contract has been fully executed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this Privacy Policy or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such Data Processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

The purposes of Processing

Personal Data belonging to the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties) or to detect any malicious or fraudulent activity. In addition, Personal Data may be used for the following, but not limited to, purposes: advertising, analytics, contacting the user, displaying content from external platforms, handling payments, location-based interactions, managing contacts and sending messages, platform services and hosting, backend infrastructure, User database management, SPAM protection, and tag management.

For specific information about how the Personal Data is used for each purpose, the User may refer to the below section “Detailed information on the Processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following Services:

Advertising

This service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on the Platform, possibly based on User interests. This does not mean that all Personal Data is used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Cookies or other Identifiers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside of the Platform. For more information, please check the privacy policies of the relevant services.

In addition to any opt-out feature offered by any of the services below, Users may opt-out by visiting the Network Advertising Initiative opt-out page.

Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ad settings in general.

Crimtan (Crimtan Holdings Limited)

• Crimtan is an advertising service provided by Crimtan Holdings Limited.
• Personal Data processed: Cookies; Usage Data.
• Place of Processing: United Kingdom – Privacy Policy – Opt-out.
• Category of personal data collected: Internet information.

Analytics

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC (“Google”). Google analyses the Data collected to track and examine the use of this Platform, to prepare reports on its activities and share them with the Owner and other Google services. Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

• Personal Data processed: Cookies; Usage Data.
• Place of Processing: United States – Privacy Policy – Opt-Out. Privacy Shield participant.
• Category of personal data collected: Internet information.

Google Analytics Advertising Reporting Features

Google Analytics has Advertising Reporting Features activated on this Platform, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyse specific behaviour and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about age and gender of Users).

Users can opt out of Google's use of Cookies by visiting Google's Ads Settings.

Personal Data processed: Cookies; unique device Identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

Place of Processing: United States – Privacy Policy – Opt-Out. Privacy Shield participant.

Category of personal data collected: Internet information and Identifiers.

Telephone contact

Users that provided their telephone number might be contacted for commercial or promotional purposes related to this Platform, as well as for fulfilling support requests.

• Personal Data processed: Telephone number.
• Category of personal data collected: Identifiers.

Displaying content from external platforms

This service allows Users to view content hosted on external platforms directly from the pages of this Platform and to interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts

Google Fonts is a typeface visualisation service provided by Google LLC that allows this Platform to incorporate content of this kind on its pages.

• Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
• Place of Processing: United States – Privacy Policy. Privacy Shield participant.
• Category of personal data collected: Internet information.

YouTube

YouTube is a video content visualisation service provided by Google LLC whose widget allows this Platform to incorporate video content on its pages.

• Personal Data processed: Cookies and Usage Data.
• Place of Processing: United States – Privacy Policy. Privacy Shield participant.
• Category of personal data collected: Internet information.

Handling payments

Unless otherwise specified, this Platform processes any payments by debit or credit card, bank transfer or other means via external payment made to Authorised Dream Draw Retailers and other appropriate service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Platform is not involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed or not.

CC Avenues Payment Solutions

• Personal Data processed: Cookies, and Credit Card information
• Place of Processing: United State Of America / United Arab Emirates

Location-based interactions

Non-continuous geolocation

This Platform may collect, use and share geographic location Data in order to provide the User with location-based services. Most browsers and devices provide tools to opt-out from this feature by default. If explicit authorisation has been provided, the User’s location data may be tracked by this Platform.

The geographic location of the User is determined in a manner that is not continuous, either at the specific request of the User or when the User does not point out its current location in the appropriate field and allows the application to detect the position automatically.

• Personal Data processed: Geographic position.
• Category of personal data collected: Geolocation data.

Managing contacts and sending messages

This service makes it possible to manage a database of email contacts, telephone contacts or any other contact information to communicate with the User.

These services may also collect Data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Airship

• Personal Data processed: Email Address, Gender and Purchase information
• Category of personal data collected: Personal marketing information

SPAM protection

This service analyses the traffic of the Platform, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.

Tag Management

This service helps the Owner to manage the tags or scripts needed on this Platform in a centralised manner. This results in the User’s Data being passed through these services, potentially resulting in the retention of the User’s Data.

User database management

This service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Platform, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social network profiles) and used to build private profiles that the Owner can display and use for improving the Platform.

Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Platform.

Further information about Personal Data

Push notifications

This Platform may send push notifications to the User to achieve the purposes outlined in this Privacy Policy.

Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing the settings for this Platform, or all of the apps on the particular device.

Users must be aware that disabling push notifications may negatively affect the utility of the Platform.

Selling goods and services online

Personal Data collected is used to provide the User with Services or to sell goods, including payment and possible delivery.

Personal Data which is collected to complete the payment may include the debit or credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Platform depends on the payment method or system used.

The rights of Users

Users may exercise certain rights regarding their Data being processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the Processing of their Personal Data.
• Object to Processing of their Data. Users have the right to object to the Processing of their Data if the Processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section “User’s rights to object to Processing”
• Access their Data. Users have the right to learn if their Data is being processed by the Owner, obtain disclosure regarding certain aspects of the Data Processing and obtain a copy of the Data undergoing Processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the Processing of User Data. Users have the right, under certain circumstances, to restrict the Processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another Data Controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another Data Controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the Processing is based on the User's consent, on a contract which the User is part of, or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users rights to object to Processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner, or for the purposes of the legitimate interests pursued by the Owner, Users may object to such Processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that Processing at any time without providing any justification. To learn, whether the Owner is Processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided at the beginning of this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

This Platform uses Cookies and other Identifiers. To learn more, the User may consult the Cookie Policy, a copy of which can be found on either the Dream Draw Website or Mobile App.

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Platform or the related Services.

The User declares to be aware that the Owner may be required to reveal Personal Data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this Privacy Policy, this Platform may provide the User with additional and contextual information concerning particular Services or the collection and Processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Platform and any third-party services may collect files that record interaction with this Platform (System logs) use other Personal Data (such as the IP Address) for these purposes.

Information not contained in this Privacy Policy

More details concerning the collection or Processing of Personal Data may be requested from the Owner at any time. Please refer to the contact details provided at the beginning of this document.

How “Do Not Track” requests are handled

This Platform does not support “Do Not Track” requests.

To determine whether any of the third party services the Platform uses honour the “Do Not Track” requests, please read their relevant privacy policies.

Changes to this Privacy Policy

The Owner reserves the right to make changes to this Privacy Policy at any time by notifying its Users on this page and possibly within this Platform and/or (as far as technically and legally feasible) sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification stated at the beginning of this document.

Should the changes affect Processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Categories of personal information collected, disclosed or sold

In this section We summarise the categories of personal information that We have collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the Processing of Personal Data” within this document.

Information We collect: the categories of personal information We collect

We have collected the following categories of personal information about You: Identifiers, internet information and geolocation data.

We will not collect additional categories of personal information without notifying You.

We collect the above mentioned categories of personal information, either directly or indirectly, from You when You use this Platform.

For example, You directly provide Your personal information when You submit requests via any forms on this Platform. You also provide personal information indirectly when You navigate this Platform, as personal information about You is automatically observed and collected. Finally, We may collect Your personal information from third parties that work with Us in connection with the Service or with the functioning of this Platform and features thereof.

How We use the information We collect: sharing and disclosing of Your personal information with third parties for a business purpose

We may disclose the personal information We collect about You to a third party for business purposes. In this case, We enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose Your personal information to third parties when You explicitly ask or authorise Us to do so, in order to provide You with Our Service.

To find out more about the purposes of Processing, please refer to the relevant sections of this Privacy Policy.

Sale of Your personal information

For Our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plug-ins and the like.

Your right to opt out of the sale of personal information

We may use Your personal information to allow the operational functioning of this Platform and features thereof (“business purposes”). In such cases, Your personal information will be processed in a manner necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use Your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the Processing of Personal Data” within this document), as well as for complying with the law and defending Our rights before the competent authorities where Our rights and interests are threatened, or We suffer an actual damage.

We will not use Your personal information for different, unrelated or incompatible purposes without notifying You.

Your privacy rights and how to exercise them

The right to know and to portability

You have the right to request that We disclose to You:

• the categories and sources of the personal information that We collect about You, the purposes for which We use Your information and with whom such information is shared;
• in case of sale of personal information or disclosure for a business purpose, two separate lists where We disclose:
  • for sales, the personal information categories purchased by each category of recipient; and
  • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If We deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable You to transmit the information to another entity without hindrance, provided that this is technically feasible.

The right to request the deletion of Your personal information

You have the right to request that We delete any of Your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Platform, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising Your right, We will delete your personal information and direct any of Our service providers to do so.

How to exercise Your rights

To exercise the rights described above, You need to submit Your verifiable request to Us by contacting Us via the contact details provided at the beginning of this document.

For Us to respond to Your request, it is necessary that We know who You are. Therefore, You can only exercise the above rights by making a verifiable request which must:

• provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorised representative;
• describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

We will not respond to any request if We are unable to verify Your identity and therefore confirm the personal information in Our possession actually relates to You.

If You are an adult, You can make a verifiable request on behalf of a minor under Your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when We are expected to handle Your request

We will confirm receipt of Your verifiable request within 10 days and provide information about how We will process Your request.

We will respond to Your request within 45 days of its receipt. Should We need more time, We will explain to You the reasons why, and how much more time We need. In this regard, please note that We may take up to 90 days to fulfil Your request.

Our disclosure(s) will cover the preceding 12 month period.

Should We deny Your request, We will explain to You the reasons behind Our denial.

We do not charge a fee to process or respond to Your verifiable request unless such request is manifestly unfounded or excessive. In such cases, We may charge a reasonable fee, or refuse to act on the request. In either case, We will communicate Our choices and explain the reasons behind it.