Privacy Policy

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Maddict FZ LLC, DMC building 10, office 303, Dubai, UAE.
• For the purpose of the GDPR, the Company is the Data Controller.
• Country refers to: United Arab Emirates, Kuwait, Qatar, Bahrain, Oman and the Kingdom of Saudi Arabia collectively the Territories.
• Data Controller, as defined under GDPR and PDPL, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
• For the purposes of PDPL (as defined below), Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
• “PDPL” mean (1) any applicable laws and regulations regarding the collection, Processing and storage of Personal data about individuals or their devices data protection or privacy from time to time, including, without limitation:
• The Personal Data Protection Law (PDPL) of the UAE Federal Decree Law No. 45 of 2021 approving resolution No. 98 issued on 20 September 2021 to become effective on 2 January 2022.
• The Personal Data Protection Law (PDPL) of KSA Royal Decree published in the official Gazette on 24 September 2021 to become effective on 17 March 2022.
• Decree No. (30) of 2018 Administrative Entity to Assume the Duties and Powers of Personal Data Protection Authority, Article 27 of Kingdom of Bahrain.
• 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 the Service, to 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. For the purpose of the GDPR, Service Providers are considered Data Processors.
• Usage Data refers to 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" means 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. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Personal Data

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: Email address, First name and last name and Usage Data.

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.

Location Data

We process pseudonymized or anonymized location signals collected from trusted data partners, such as: Mobile app partners, SDK / location service providers, Aggregated mobility providers and/or Third-party data aggregators.

The location data typically includes: GPS coordinates, Wi-Fi or cell tower signals, Timestamp of the observation and Device-level identifiers (hashed or pseudonymized). We do not receive directly identifiable personal information such as names, phone numbers, or email addresses.

To ensure product reliability and security, we may process: Device type, Operating system, Network information and/or IP addresses (anonymized or truncated where required).

Use of Your Personal Data

The Company may use Personal Data to provide and maintain our Service, that includes:

• Advertising & Marketing Analytics such as Build audience segments, Provide advertisers with anonymized insights and/or Deliver contextual and interest-based advertising.
• Measurement & Reporting such as Analyze footfall and mobility trends, Measure campaign effectiveness and/or Provide aggregated reports to clients.
• Data Security & Operational Integrity: Prevent fraud or misuse, Monitor and secure our systems and/or Conduct audits and incident response.
• Compliance with PDPL Requirements: Maintain processing records, Respond to data subject requests, Conduct impact assessments.

Miscellanous such as

• To 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.
• For the 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.
• To contact You: To contact You by email, or other equivalent forms of electronic communication, such as 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.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, and to evaluate and improve our Service, products, services, marketing and your experience.
• We may share Your personal information in the following situations: 1) For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company. 2) With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company 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.

Retention periods vary by data type, but location data is generally retained for 12–24 months, after which it is deleted or irreversibly anonymized.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's 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.

The Company 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. Please refer to “Maddict Security Frameworks and best practice standard.”

We may share aggregated insights with: Advertisers, Agencies, DSPs / SSPs / DMPs, Publishers and OOH media owners and Measurement and analytics partners. We do not share raw device-level location data.

All partners must adhere to strict contractual data protection terms, including: Prohibition of re-identification, Use only for approved purposes, Compliance with privacy regulations.

Disclosure of Your Personal Data

Business Transactions. If the Company is 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, the Company 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. The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: 1) Comply with a legal obligation 2) Protect and defend the rights or property of the Company 3) Investigate possible wrongdoing in connection with the Service 4) Protect the personal safety of Users of the Service or the public 5) Protect against legal liability.

Security of Your Personal Data

The security of Your Personal Data is important to Us but remember 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 have access to your personally identifiable and Location information, you may view or delete and in appropriate instances update or correct your PII and email preferences at any time.

To protect your privacy and security we take reasonable steps to verify before granting Users profile access. YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF YOUR UNIQUE PASSWORD AND ACCOUNT INFORMATION AT ALL TIMES.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Data Minimization & Anonymization

We apply rigorous transformation layers before any modeling or segmentation:

• Removal of directly identifiable information
• Pseudonymization and hashing of device identifiers
• Spatial/temporal aggregation
• Downsampling or noise addition where appropriate
• Strict limitations to prevent re-identification

We never attempt to identify individual users.

Storage & Security (GCP Infrastructure)

Our entire infrastructure is hosted on Google Cloud Platform (GCP). We implement enterprise-grade technical and organizational safeguards including:

• Data encryption in transit (TLS) and at rest (AES-256)
• VPC-level network segmentation
• IAM & role-based access control
• Audit logging & monitoring
• Secret rotation and key management using GCP KMS
• Regular security testing and vulnerability management

GCP maintains compliance with major standards (ISO 27001, SOC 2, GDPR-aligned processing, etc.).

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the 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.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

PDPL Privacy

This privacy notice section for UAE, KSA and Bahrain residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the UAE, KSA or Bahrain as applicable.

Legal Basis for Processing Personal Data under UAE PDPL

We may process Personal Data under the following conditions:

• Consent: You have given explicit and clear consent for processing.
• Contractual Necessity: Processing is necessary to perform a contract with the data subject or to take steps at the request of the data subject before entering into a contract.
• Legal Obligation: The processing is required to comply with a legal obligation imposed by UAE laws.
• Protection of Public Interest: Processing is necessary for public interest purposes, such as national security or public health.
• Legitimate Interests: Processing is necessary for the legitimate interests of the data controller or a third party, provided it does not override the rights of the data subject.
• Vital Interests: Processing is required to protect the life or safety of the data subject or another person.
• Judicial and Security Requirements: Processing is required by authorities for judicial or law enforcement purposes.

Your Rights under the UAE PDPL

You have the right under this Privacy Policy, and by law if You are within the UAE, to:

• Right to Access: You can request access to your personal data held by the Company.
• Right to Rectification: You have the right to correct inaccurate or incomplete personal data.
• Right to Erasure: You can request the deletion of your personal data under certain conditions.
• Right to Restriction of Processing: You can request to limit the processing of your data in specific circumstances.
• Right to Data Portability: You can request your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You can object to the processing of your personal data, including for direct marketing purposes.
• Right to Withdraw Consent: Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
• Right to Lodge a Complaint: You can file complaints with the UAE Data Office if you believe your data protection rights have been violated.

2. KSA Personal Data Protection Law (PDPL) – Royal Decree (Official Gazette on 24 September 2021)

Legal Basis for Processing Personal Data under KSA PDPL

We may process personal data if one of the following conditions applies:

• Explicit Consent: You have given clear, specific, and unambiguous consent.
• Contractual Necessity: Processing is required to fulfill a contract or to take steps requested by yourself before entering into a contract.
• Legal or Regulatory Obligation: Processing is necessary to comply with Saudi laws or regulatory requirements.
• Vital Interests: Processing is required to protect the life or health of the data subject or another person.
• Public Interest: Processing is necessary for public interest reasons, including national security, public health, or law enforcement.

Your Rights under the KSA PDPL

You have the right under this Privacy Policy, and by law if You are within the Kingdom of Saudi Arabia to:

• Right to Access: You have the right to request and obtain a copy of your personal data.
• Right to Correction: You can request the correction or updating of inaccurate or incomplete personal data.
• Right to Deletion: You may request the deletion of your personal data in certain situations, such as if the purpose of processing is fulfilled.
• Right to Restrict Processing: You can request to limit how your data is processed in specific cases.
• Right to Object: You can object to the processing of your personal data, including for direct marketing or automated decision-making.
• Right to Withdraw Consent: If processing is based on consent, you can withdraw your consent at any time.
• Right to Complain: You have the right to file complaints with the Saudi Data and Artificial Intelligence Authority (SDAIA) if you believe your data protection rights have been violated.

3. Bahrain’s Data Protection Law – Decree No. (30) of 2018

Legal Basis for Processing Personal Data under Bahrain PDPL

We may process personal data if one of the following conditions applies:

• Consent: The data subject has provided informed, freely given consent.
• Contractual Necessity: Processing is required for contract performance or to take pre-contractual steps requested by the data subject.
• Legal Obligation: Processing is necessary to comply with Bahrain’s laws.
• Vital Interests: Processing is needed to protect the life or health of the data subject or another person.
• Legitimate Interest: Processing is necessary for the legitimate interests of the data controller, provided it does not override the rights of the data subject.
• Public Interest or Official Authority: Processing is required for tasks carried out in the public interest or by an official authority.

Your Rights under the KSA PDPL

You have the right under this Privacy Policy, and by law if You are within Bahrain, to:

• Right to Information: You must be informed of how your data is being processed.
• Right to Access: You can request access to your personal data.
• Right to Rectification: You can request the correction of inaccurate personal data.
• Right to Erasure (Right to Be Forgotten): You can request the deletion of your personal data if processing is no longer necessary.
• Right to Object: You can object to the processing of your data, particularly for direct marketing.
• Right to Data Portability: You can request your personal data in a structured format.
• Right to Restriction of Processing: You can limit how your data is processed in certain cases.
• Right to Withdraw Consent: If data processing is based on consent, you can withdraw it at any time.
• Right to Lodge a Complaint: You can file complaints with the Personal Data Protection Authority in Bahrain.

Children's Privacy

Our Service does not address anyone under the age of 15. We do not knowingly collect personally identifiable information from anyone under the age of 15. 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 15 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

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.

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.