MOJO Platform Privacy Policy

Last version: 27 June 2022

The Mojo platform www.getmojoapp.com (the “Platform”) is owned and operated by Mojo Digital for Auctions Company and/or its affiliates (hereinafter called “Mojo”) and specializes in providing online shopping, live e-commerce and marketing services and other related services in the Middle East and North Africa (collectively "Mojo Services").

Your privacy is important to us, so we have developed this Privacy Policy that covers how we collect, use, disclose, transfer, store and delete your personal information when you are using the Mojo Platform and related Mojo Services. You should review the entirety of this Privacy Policy and our Conditions of Use before using the Platform. If the processing of personal data as described in this Privacy Policy is not acceptable to you, do not use or continue using the Platform and/or submit your personal information.

The Platform is meant to provide you access to online shopping, live e-commerce, and access to marketing and advertisement content pertaining to third party sellers and other related services. Therefore, the Platform must collect relevant personal information to provide such services.

Collection and Use of Personal Information

Personal information is data that can be used to identify or contact a single person. You may be asked to provide your personal information (pursuant to our Conditions of Use) when using the Platform. Mojo and its affiliate, including the Sellers may share this personal information with each other and use it consistent with this Privacy Policy in providing you with products and services. Mojo and its affiliates may also combine it with other information to provide and improve our products, services, content and advertising. You are not obligated to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

What personal information we collect

When you create an account on the Mojo Platform, visit our website, download a software update, register to receive promotional content, connect to our services, or contact us, we may collect a variety of information from you, including: your name, date of birth, mailing and work addresses, phone number, email address, contact preferences, device identifiers, Internet Protocol (IP) address, location information, credit card information and profile information.

·       When you register a minor under your guardianship and thereby share another individual’s personal information with us (which we will assume you have obtained permission or have the authority to do), Mojo may collect the information you provide about those individuals such as their name, date of birth, mailing address, email address and phone number. Mojo will use such information to fulfill your requests, provide the relevant service, or for anti-fraud purposes.  

·       We may ask for government issued identification when you create an account on the Mojo Platform for the purpose of verifying your identity, or as required by law.

How we use your personal information

·       With your consent, we may process your personal information to provide our products and services, for the purposes described in our Conditions of Use and this Privacy Policy, for compliance with a legal obligation to which Mojo is subject, for the performance of a contract to which you are party, in order to protect your vital interests, or when we have assessed it is necessary for the purposes of the legitimate interests pursued by Mojo or a third party to whom it may be necessary to disclose information.

·       The personal information we collect also allows us to keep you updated on our latest product announcements, software updates, and upcoming events. If you do not want to be on our mailing list, you may opt-out at any time by modifying your account settings.

·       We also use personal information to help us create, develop, operate, deliver and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes.

·       We may also use your personal information for account and network security purposes, including to protect our products and services for the benefit of all our users. Where we use your information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services such as during the conduct of an online transaction with us. For certain online transactions we may also validate the information provided by you with publicly accessible sources.

·       We may use your personal information, including your date of birth, to verify identity, assist with identification of users, and to determine appropriate products and services. For example, we may use date of birth to determine the age of the Mojo account holders.

·       From time to time, we may use your personal information to send important notices, such as communications about purchases made, comments and reviews that you have provided and changes made to our terms, conditions, and policies. Because this information is important to your interaction with Mojo, you may not opt-out of receiving these communications.

·       We may also use personal information for internal purposes such as for auditing, data analysis and research to improve Mojo’s products, services, and customer communications.

Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we may collect and how we intend to use it:

·       We may collect information such as occupation, language, unique device identifier, referrer Uniform Resource Locators (URLs), and location where the Mojo Platform or Mojo Services product are used so that we can better understand customer behavior and improve our products, services and advertising.

·       We may collect information regarding customer activities on our application or website and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products and services are of most interest. Aggregated data is considered non-‑personal information for the purposes of this Privacy Policy.

·       We may collect and store details of how you use our products and services including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.

·       We may collect data about how you use your device and our applications in order to help our application developers improve our applications and products.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

Cookies and Other Technologies

The Mojo Platform, website, online services and electronic messages may use “cookies” and other technology such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of web searches. We treat information collected by cookies and other technologies as non-personal information. However, to the extent that IP‑ addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

The Mojo domains may also use cookies and other technologies to remember personal information when you use our website, services, products, online services and applications. Our goal in these cases is to make your experience with Mojo more convenient and personal. For example, knowing your contact information, hardware identifiers, and information about your computer or device helps us personalize your operating system and provide you with better customer service.

If you want to disable cookies, you may modify your browser settings. Please note that if you disable the cookies you will alter your experience with our application and certain features of the Mojo Platform and website will not be available once cookies are disabled.

As is true of most internet services, we gather some information automatically and store it in log files. This information includes IP addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date and timestamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base. Mojo may also use this information in our marketing and advertising services.

In some of our email messages, we use a “click-through URL” linked to content on the Mojo website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular products, content or topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format that the customer can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

Disclosure to Third Parties

Mojo will provide the Sellers (as defined under the terms and conditions) and third party service providers with certain of your personal information in order to administer or provide the services that you are requesting, including purchasing products and services, finalising payment transactions, or to improve our services, or to have products requested or ordered delivered to you. Those third parties are obliged to handle such information in accordance with applicable laws. Personal information may also be shared with third parties for their marketing purposes. For example, when you create a Mojo account, access certain content, request certain content or inquire about certain products, you authorize Mojo to exchange the information you provide during the Mojo account activation process with the related third party in order to provide the service, including information about your device. If your request or order is accepted, your interaction will, among other things, be governed by Mojo, the Seller’s, the payment gateway provider’s, and (if applicable) the shipper’s respective privacy policies.

In order for you to receive the services or the products you have ordered from the Sellers on the Mojo Platform, we shall have to transfer your relevant personal information to the said Seller or other third parties service provider. The way this Personal Information will be collected, used, disclosed, transferred, stored and deleted shall be subject to the privacy policies and practices of the Seller or other third party service providers. 

Sellers

Mojo shares personal information with Sellers who provide services such as providing products and services, fulfilling of customer orders, delivering of products to you (pursuant to the sellers terms and conditions), management and enhancement of customer data, processing of information, provision of customer service, assessment of customer interest in products and services and conduct of customer research or satisfaction surveys. These companies are obligated to protect your information and may be located outside of Kuwait.

Payments

The products and services promoted via the Mojo Platform include paid services which are processed through third-party processors. Mojo may store your payment card details and that information is provided directly to our third-party payment processors, whose use of your personal information is governed by their Privacy Policy, during an online transaction. These payment processors typically adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard and American Express. PCI-DSS requirements help ensure the secure handling of payment information.

Others

Where applicable, it may be necessary by law, legal process, litigation, and/or requests from public and governmental authorities within for Mojo to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect you or our operations or users.  This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Protection of Personal Information

Mojo takes the security of your personal information seriously. Mojo’s Platform and online services and website protect your personal information during transit using encryption and other data security measures that are Health Insurance Portability and Accountability Act (HIPAA) compliant. When your personal data is stored by Mojo, we use computer systems with limited access housed in facilities using physical security measures. The data we collect is stored in encrypted form including when we utilize third-party storage. It should however be remembered 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 information, we cannot guarantee its absolute security and infallibility. You are responsible for the personal information you choose to share or submit to others online or offline. Mojo will not take responsibility for your decision to make any personal information public.

Integrity and Retention of Personal Information

Mojo makes it possible for you to keep your personal information accurate, complete, and up-to-date. We will retain your personal information for the period necessary to fulfill the purposes it is collected for and as outlined in this Privacy Policy. When assessing this period, we carefully examine the reason such personal information was collected and if we establish a relevant need, we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.

Access to Personal Information

You can help ensure that your information is accurate, complete, and up-to-date at any time. For the personal information we hold, we will provide you with access, including a copy, for any purpose including to request that we correct the data if it is inaccurate or delete the data if Mojo is not required to retain it by law or for legitimate business purposes.

We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier. Unless restricted by law or otherwise, you may request from us the deletion of your personal information. That information will be removed from our active database. However, Mojo reserves the right to keep and use de-identified data as permitted under this Privacy Policy. A request for deletion may be sent to support@getmojoapp.com .

Children

Individuals under the age of 21 (or, if appropriate in your country of residence, 18) are not permitted to create their own Mojo accounts, unless their parent or guardian have provided verifiable consent, and such individuals must be placed under a parental account. In such case, the parent or guardian must review the Mojo Platform and website Conditions of Use and this Privacy Policy before they can begin the Mojo account creation process for their child. If we learn that we have collected the personal information of an individual under 21 outside the above circumstances, we will take steps to delete the information as soon as possible.

Location-Based Services

To provide location-based services via the Mojo Platform where applicable, Mojo and the Sellers, may collect, use, and share precise location data, including the real-time geographic location of your computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your device’s approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by Mojo and the Sellers to provide and improve location-based products and services. For example, your device may share its geographic location with the Mojo Platform when you opt-in to its location-based services. Some location-based services offered by Mojo require your personal information for the feature to work.

Third-Party Sites and Services

The Mojo Platform, websites, applications and services may contain links to third-party websites, products, and services. The Mojo Platform also offers products and services from the Sellers and other third parties. Information collected by such parties, which may include your personal information is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties before engaging with them.

International Transfer of Information

All the information you provide may be transferred to or accessed by other entities as described in this Privacy Policy. Mojo will take all reasonable steps necessary to ensure that your information is treated securely and in accordance with this Privacy Policy. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Our Company-wide Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to all Mojo employees and strictly enforce privacy safeguards within the company.

Privacy Questions

If you have any questions or concerns about the Mojo Privacy Policy or data processing, or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at support@getmojoapp.com .

All such substantive contacts receive a response within seven (7) business days on average wherever possible - providing a response on the issue raised, requesting additional information where necessary or indicating that a response may require additional time.

Where your complaint indicates an improvement that could be made in our handling of privacy issues, we will take steps to make such change at the earliest next reasonable opportunity. If a privacy issue has resulted in a negative impact on you or another person, we will take steps to address that with you or that other person.

Mojo may update this Privacy Policy from time to time and on an as-needed basis. When we change the policy, a notice will be posted on the Mojo Platform and our website along with the updated Privacy Policy.

THE Mojo Platform and website is owned, operated and maintained by Mojo Digital for Auctions Company, having commercial registration No. 448340, with offices at Office A, Floor 59, Al Hamra Tower, Sharq, Kuwait.