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    Effective Date: 01.10.2023

    Welcome to https://eighty6.tech (the “Website”) and Eighty6 application (the “Platform”), (altogether the “Site”). Please read the following Terms of Use carefully before using this Site so that you are aware of your legal rights and obligations with respect to Eighty6. (“Eighty6”, “we”, “our” or “us”).

    This Privacy Policy explains how we collect, use, disclose, transfer and store Personal Information in connection with our Site and the related content, services, subscription and other functionality offered on or through the Website, Platform, and our online services (collectively, the “Services”).

    1. Scope of Personal Information

      When we use the term “Personal Information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

    2. Our Collection of Personal Information

      We collect Personal Information about individuals when they visit our Site or create an account. Sometimes we collect Personal Information automatically when an individual interacts with our Services and sometimes we collect it directly from an individual. At times, we may collect Personal Information about an individual from other sources and third parties, even before our first direct interaction.

      1. From the Site

        The Personal Information we collect that is submitted to us by visitors to our Site:

        • Contact Information, including first name, last name, employer, title, account status, email address, mailing address, phone number and communication preferences.
        • Inquiry Information, including information provided in custom messages sent through the forms or contact information provided on our Site.

        We may collect information through a variety of data collection technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “cookies”). The Personal Information we and our third-party providers collect automatically:

        • Log File Data, including IP address, operating system, browser type, browser id, the URL entered and the referring page, date/time of visit, the time spent on our Site and any errors that may occur during the visit to our Site.
        • Analytics Data, including the electronic path taken to our Site, through our Site and when exiting our Site, as well as usage and activity on our Site, such as the links and objects viewed, clicked or otherwise interacted with (also known as “Clickstream Data”).
        • Location Data, including general geographic location based on the log data we or our third-party providers collect.
      2. From the User Accounts

        We collect Personal Information from our users and prospective users in connection with the user accounts and ongoing maintenance of the accounts, which includes:

        • Online Account Information, including username and password, as well as associated security questions and answers.
        • Contact Information, including first name, last name, title, employer, email address, mailing address, phone number and communication preferences, as well as any information provided when signing up for special offers from selected third parties.
        • Account Support Information, including Personal Information provided when contacting us in connection with our Services.
      3. From Third Parties

        We may receive and collect the same categories of Personal Information as described above from the following third parties:

      4. From Business Partners: Our business partners may collect Personal Information in connection with the Services provided and may share some or all of the information with us.
      5. From Restaurants and Suppliers: If you are using the Services in connection with your role as a Restaurant, we may receive your information from your Supplier.
      6. From Social Media Partners: When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook, Instagram or follows us or shares our content on a social network platform, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network.
      7. It is important to note that we display targeted advertising to individuals through social media platforms, such as Facebook, Instagram and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to an individual or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If an individual does not want to receive targeted ads on their social networks, they may be able to adjust their advertising preferences through their settings on those networks.

        • From Service Providers: Our service providers that perform services solely on our behalf, such as analytics providers. For example, we receive Personal Information from our service providers that conduct marketing or analytics activities.
        • From Other Third Parties: From time to time, we may receive information about individuals from third parties such as marketing partners or from third parties to enhance or supplement our existing information about an individual. We may also collect information about individuals that is publicly available. We may combine this information with the information we collect directly from individuals.
        • From Third Party Advertising Companies: We participate in interest-based advertising and use third-party advertising companies to serve targeted advertisements based on an individual’s browsing history. We permit third-party online advertising networks, social media companies and other third-party services, to collect information about an individual’s use of our online Services over time so that they may play or display ads on other websites, or services an individual may use, and on other devices an individual may use. Typically, though not always, the information used for interest-based advertising is collected through data collection technologies, such as Cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device an individual is using and collect information, including click stream information, browser type, time and date the individual visited the website, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify an individual across devices.
    3. Our Use of Personal Information

      We use Personal Information we collect to:

      • Provide and monitor the effectiveness of our Services, answer users’ questions and resolve their problems;
      • Manage our organization and its day-to-day operations;
      • Communicate with individuals, including via email, text message, social media and/or telephone calls;
      • Request individuals to complete surveys about our service offerings;
      • Market our Services to individuals, including through email, direct mail, phone or text message;
      • Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Site;
      • Operate, maintain and provide the features and functionality of the Services;
      • Monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Services
      • Determine an individual’s eligibility for and/or proof of enrollment in our Services;
      • Create and maintain accounts for our members;
      • Facilitate user benefits and Services, including user support through our command center services;
      • Identify and analyze how individuals use our Site and Services;
      • Conduct research and analytics on our user base and our Services;
      • Improve and customize our service offerings to address the needs and interests of our user base and other individuals we interact with;
      • Make the advertisements an individual sees online more relevant to their interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research;
      • Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
      • Help maintain the safety, security and integrity of our property and Services, technology assets and business;
      • Defend, protect or enforce our rights or applicable contracts and agreements;
      • Prevent, investigate or provide notice of fraud or unlawful or criminal activity; and Comply with legal obligations.
    4. Our Disclosure of Personal Information

      We may disclose Personal Information to the following:

      • To our Affiliates: We may share Personal Information with other companies owned or controlled by us, and other companies owned by or under common ownership, which also includes our subsidiaries and our ultimate holding company.
      • To Your Employer: If you are using the Services in connection with your role as an employee or contractor of a company or other legal entity, we may share your information with such entity.
      • To Your Supplier: If you are using the Services in connection with your role as a Restaurant, we may disclose your information to your Supplier in conjunction with processing a purchase order, or responding to an inquiry.
      • To Service Providers: We share Personal Information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries. We engage third-party service providers that perform business or operational services for us or on our behalf, such as cloud hosting, IT services, analytics services, administrative services.

      For instance, we use Firebase Analytics to recognize an individual and link the devices they use when they visit our websites or Services on their browser or mobile device, log in to their account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Firebase to facilitate the Services. Firebase Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to an individual.

      We also utilize Amazon Web Services (AWS) for cloud infrastructure, storage and computing power to enhance the reliability and scalability of our Services. While AWS primarily provides infrastructure services and does not access or use Personal Information stored on its servers, certain non-Personal Information related to our Services, such as application performance metrics and system logs, may be processed and stored on AWS infrastructure. This allows us to efficiently deliver our Services, ensuring a seamless user experience.

      We may also use the services of Google Analytics 4 (GA4) to collect information about an individual’s use of our Services and analyze such information for the purpose of enhancing and maintain the quality of the Services. We may share certain Personal Information with GA4 for the purpose of utilizing its analytics tools.

      The collection and use of such information is governed by the privacy policies of those third party service partners. We do not control the processing of those third-party service providers and you are encouraged to review their privacy policies and terms of service for more information on how they handle personal information.

      • To Other Third Parties: We may disclose Personal Information to third parties who use this information to provide information or marketing messages about products or Services of interest, in accordance with their own privacy policies and terms.
      • To Legal Advisors and Law Enforcement Authorities: We may disclose Personal Information to third parties, such as legal advisors and law enforcement:
        • in connection with the establishment, exercise, or defense of legal claims;
        • to comply with laws or to respond to lawful requests and legal process;
        • to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
        • to detect, suppress, or prevent fraud;
        • to protect the health and safety of us and others; or
        • as otherwise required by applicable law.
      • Otherwise With Your Consent: We may disclose Personal Information about an individual to certain other third parties or publicly with your consent or direction. For example, with an your consent or direction we may post your testimonial on our Site or service-related publications.
    5. International Transfers of Personal Information

      As part of our Services, your Personal Information may be transferred to and processed in countries other than your own, including but not limited to the United Arab Emirates. We take measures to ensure that any such international transfers comply with applicable data protection laws and regulations. These measures may include the appointment of a data protection officer, who shall ensure compliance as required by applicable law, and other legal mechanisms as required.

    6. Storage of Personal Information

      We prioritize the security and integrity of your Personal Information. This section outlines how we store and protect your Personal Information.

      • Data Storage Practices: We store your Personal Information on secure servers and databases, either owned and maintained by us or by trusted third-party service providers. These servers and databases are designed to safeguard your data from unauthorized access, disclosure, alteration, or destruction.
      • Data Retention: We retain your Personal Information only for as long as needed to fulfill the purposes for which it was collected and to comply with legal, accounting, or reporting requirements. Once your Personal Information is no longer needed for these purposes, we take steps to securely delete or anonymize it.
      • Data Backup: To ensure data availability and resilience, we regularly back up your Personal Information. These backups are encrypted and stored in secure locations to protect against data loss.
      • Third-Party Storage: In some cases, we may rely on third-party service providers for data storage. These providers are chosen based on their commitment to data security and privacy. They are contractually obligated to adhere to our data protection standards.
      • Data Security Incidents: In the event of a data security incident or breach, we have established procedures and protocols to promptly investigate, notify affected individuals and authorities as required by applicable laws, and take appropriate measures to mitigate the impact of the breach.
      • Your Data Management Preferences: You have the ability to manage certain aspects of your data stored within our platform. For more information on how to access, correct, update, or delete your Personal Information, please refer to our “Your Privacy Rights” section in this privacy policy.
      • We are committed to maintaining the confidentiality and security of your Personal Information throughout its storage and retaining it only for as long as needed. For any questions or concerns regarding the storage of your Personal Information, please contact us at info@eighty6.tech
    7. Your Privacy Rights
      • Access to Your Information: You have the right to request access to the Personal Information we hold about you. If you would like to review, verify, correct, or request a copy of your Personal Information, please contact us using the contact information provided at the end of this Privacy Policy.
      • Correction of Your Information: You have the right to have any inaccuracies in your Personal Information corrected. If you believe that any of the information we hold is inaccurate or incomplete, please contact us, and we will promptly take corrective action
      • Deletion of Your Information: You have the right to request the deletion of your Personal Information, subject to applicable legal requirements. If you wish to have your Personal Information deleted, please contact us, and we will assess your request in accordance with applicable laws.
      • Data Portability: You have the right to request a copy of your Personal Information in a structured, commonly used, and machine-readable format for the purpose of transferring it to another organization. If you would like to exercise this right, please contact us.
      • Objection to Processing: You have the right to object to the processing of your Personal Information under certain circumstances, such as when we are relying on our legitimate interests as the legal basis for processing. If you wish to object to the processing of your Personal Information, please contact us, and we will review your request in accordance with applicable laws.
      • Withdrawal of Consent: If you have provided your consent for the processing of your Personal Information, you have the right to withdraw your consent at any time. To withdraw your consent, please contact us. Please note that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
    8. Your Choices about Cookies and Online Ads
      • Cookies: To manage cookies, you may change your browser settings to: (i) notify you when you receive a cookie, so that you can choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our Site, as some features and Services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
      • Online Advertisement: We allow an individual to exercise choice regarding the collection of information about their online activities over time and across third-party websites for online interest-based advertising purposes. If an individual wants to “opt out” of receiving online interest-based advertisements on their internet browser from advertisers and third parties, please let us know.
    9. Children’s Personal Information

      Our websites and online Services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Information from children under the age of 18. If an individual is under the age of 18, they should not use our websites or online Services or otherwise provide us with any Personal Information either directly or by other means. If a child under the age of 18 has provided Personal Information to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Information from our systems. If we learn that any Personal Information we collect has been provided by a child under the age of 18, we will promptly delete that Personal Information.

    10. Links to Third-Party Websites or Services

      Our Site and Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Information practices of third parties, please visit their respective privacy notices.

    11. Updates to this Privacy Policy

      We will update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on this website or our online Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

    12. Contact Us

      For any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to info@eighty6.tech.