Privacy Policy — How Goldady Protects Your Data

GOLDADY PRIVACY POLICY

PLEASE READ THESE TERMS OF SERVICE CAREFULLY BEFORE ACCESSING OR USING THE SITE AS THEY CONTAIN IMPORTANT INFORMATION REGARDING YOUR LEGAL RIGHTS, REMEDIES AND OBLIGATIONS. THESE TERMS SHOULD BE READ AND ACCEPTED IN CONJUCTION WITH ANY OTHER TERMS AND CONDITIONS PROVIDED IN THE SITE (AS APPLICABLE) WHICH TOGETHER CONSTITUTE A SINGLE SET OF TERMS AND CONDITIONS FOR THE USE OF THE SITE.

The User's use of the Site and/or registration for GD Egypt for metals trade (hereinafter referred to Goldady”) Services constitutes his/her/its consent to the terms of this Privacy Policy. Users are deemed to have fully and unreservedly accepted this Privacy Policy once they tick the box "I agree to Goldady’s Terms and Conditions" when creating their User accounts. If this box is not ticked, it will be impossible to create a User account or use the Goldady services, which Users acknowledge.

Goldady reserves the right to modify the Privacy Policy at any time, in which case the changes become effective when they are published on the Site. Continued use of the Site constitutes Users’ implicit acceptance of the latest updated version of the Privacy Policy.

If the User provides personal information of any third party to Goldady, this latter would assume that the User have obtained the required consent from the relevant third party to share and transfer his/her/its personal information to Goldady.

This privacy policy tells you how we process your personal data when you use our website and our apps and when we communicate with you and gives you information about our use of cookies and similar tracking technologies.

when the User creates a Goldady account, or otherwise provide Goldady with his/her/its personal information through the platform, the personal information Goldady collects may include:

Full accurate name
Identification number and/or details
Company’s name and commercial registry information (if any)
Account details and related contact information
Postal address
Telephone or fax number
Email address and other identifying addresses for electronic communications
Date of birth
Details from national identification cards and passports and other government forms of personal identification
Telephonic or electronic recordings
Browser and device information
App usage data
Information collected through cookies, pixel tags, google tags and other technologies
Demographic information
Survey responses and similar information which reveals views and preferences

We and our service providers collect the above information in a variety of ways. This includes information provided by you directly and:

Through a browser or device: Certain information is collected by most browsers or automatically through devices, such as a Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the services (such as the app) being used. We also collect your IP address, which is automatically assigned to a computer by an Internet Service Provider. An IP address will be identified and logged automatically in our server log files whenever a user accesses any of our services, along with the time of the visit and the page(s) that were visited. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and for administration purposes. We also derive approximate location from IP address for such purposes and to analyze where users are using our website, apps and services.
Using cookies and similar technologies: See the Cookies and Similar Technologies section below.
From third parties: See the following section.
If you correspond with us via e-mail, we retain a copy of such correspondence for internal use. The information collected is also used to provide a record of communications between you us and to comply with any applicable legal and/or regulatory requirements.

Do we collect personal data about you from third parties?

We also collect your personal data from third parties:

from our group companies (whose identities can be found in the link in the who do we share your personal data with? section below);
from publicly accessible sources, including publicly available online profiles and databases e.g. to establish and verify your identity, to find out your contact details to supplement the contact information we have about you and to liaise with you in relation to our products and services; and
by using third party cookies – this is explained further in the ‘Cookies and similar technologies’ section below.

How do we use your personal data?

We use your personal data:

to perform our contract with you or to take steps linked to a contract, such as servicing your account;
to pursue our legitimate interests which do not override your interests or fundamental rights and freedoms, such as:

to operate and administer our website and apps;
to provide products and services to our clients and to communicate with you and/or our clients about them;
improving and developing the products and services we provide;
providing information to you about our and/or our group companies services and products or anything else (e.g. additional products and services) that we think may be of interest to you/our clients (this information may be provided to you in the form of a digital advertisement and campaigns or via email or SMS)
to identify which products or services we think you are interested in by using cookies on our website which track and analyse how you use our website;
keeping a record of your communications with us for the purposes of your relationship with us and the services we provide;
administration, assessment and analysis purposes;
to check and verify your identity;
to monitor and analyze the use of our products and services and website and apps for system administration, operation, testing and support purposes;
to manage our information technology and to ensure the security of our website, apps and systems;
to establish, exercise and/or defend legal claims or rights and to protect, exercise and enforce our rights, property or safety, or to assist our clients or others to do this; and
to investigate and respond to complaints or incidents relating to us or our business, to maintain service quality and to train staff to deal with complaints and disputes;
to check compliance with and enforce our terms and conditions or other contractual terms; and
in relation to any proposed purchase, merger or acquisition of any part of our business;

c) to comply with our legal obligations laid down in laws applicable to us including applicable regulations, market rules, any other legal authority in Egypt or in any other jurisdiction where we (or any of our affiliates) may operate.
Goldady may hire affiliates or other third parties to provide some products and/or services on Goldady’s behalf, then Goldady will provide those companies only the personal information they need for the identified purposes, and Goldady will limit their rights to use and further disclose his/her/its personal information as appropriate in the course of their work for Goldady.
as explained in the Cookies and Similar Technologies section below. We obtain your consent for the use of non-essential cookies. You have the right to withdraw your consent at any time. By not providing consent or withdrawing your consent, certain aspects or features of our website may not be available to you. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

In relation to b), we have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests. You can obtain information about the balancing test we have undertaken by contacting us using the details at the end of this privacy policy.

In order for us to provide you with certain services, including but not limited to intermediation and research services, which require us to process your personal data due to regulatory and legal requirements (for example KYC and AML) the provision of information is mandatory.

If relevant data is not provided to us, then we will not be able to provide you with the full range of our services meaning that our services may only be offered with a limited scope or not at all. All other provisions of your information are optional.

Limiting The Collection Of Personal Information

Goldady limits its collection of personal information only to the fact that the information is necessary for the identified purposes. Goldady does not direct its site to, nor does it knowingly collect any personal information from persons under the age of eighteen (18 years).

Cookies and similar technologies

Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page. Other tracking technologies are also used which are similar to cookies. This can include pixel tags and tracking URLs. All these technologies are together referred to in this Policy as “Cookies”.

The types of Cookies that we use on our website, and the purposes for which they are used, are set out below:

Strictly necessary cookies: These cookies are essential in order to enable you to move around our website and use its features, such as accessing secure areas of our website. Without these cookies, any services on our Site you wish to access cannot be provided.
Analytical/performance cookies: These cookies collect information about how you and other visitors use our website, for instance which pages you go to most often, and if you get error messages from web pages. We use data from these cookies to help test designs and to ensure a consistent look and feel is maintained on your visit to the website. All information these cookies collect is aggregated. It is only used to improve how a website works. We use Google Analytics, for example, to anonymously track website usage and activity.
Functionality cookies: These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They are also used to provide services you have asked for such as watching a video or commenting. Additionally, these Cookies can be used to allow an optional service to function. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Targeting cookies: These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
Social media cookies: These cookies allow you to share what you’ve been doing on our website on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.
Pixel tags: Also known as a clear GIF or web beacon. These are invisible tags placed on certain pages of our website but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, registering when a particular device visits a particular page. They are used to, among other things, track the actions of users of our services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of our services and response rates. If you turn off cookies, the pixel tag will simply detect an anonymous website visit.

To find out more about Cookies please visit: www.allaboutcookies.org which contains further information about behavioural advertising and online privacy.

For how long do we keep your personal data?

We only keep your personal data for as long as is necessary to fulfill the purposes for which it has been collected. When determining the appropriate retention period, we consider the risks of the processing, our contractual, legal, and regulatory obligations, internal data retention policies, and our legitimate business interests as described in this privacy policy.

Where we process data for (i) registration purposes, (ii) support purposes, or (iii) in order to customize your website experience, we keep this data for the duration of the period where you are a user and for an additional five-year period from when you cease to be a user.

Where we process data for marketing purposes we will do so unless we receive a request from you to stop. We will hold a record of such data for five years from when you request us to stop.

Where we process data for website security, we hold this data for a maximum period of one year.

Who do we share your personal data with?

Where we send direct marketing materials to you, we send your personal data to third parties with whom we have contracted to provide these materials to you on our behalf and in our name.

We also share your personal data with:

service providers, who provide a service to us or you
their service providers, delegates and agents.

We also disclose your personal data to:

regulators, exchanges, auditors, courts, the police, or other law enforcement agencies where we are legally obliged to do so;
to other persons where disclosure is required by law or to enable products and services to be provided to you or our clients; and
our professional service providers (e.g., legal advisors, accountants, auditors, insurers and tax advisors) where relevant.

If it becomes relevant, we will share your personal data with a potential buyer and their advisers in connection with any proposed purchase, merger, or acquisition of any part of our business.

What are your rights in relation to the personal data we process about you?

Subject to the conditions prescribed in applicable laws, you have the right: (i) to access, rectify or request the erasure of your personal data; (ii) to ask us to restrict the processing of it; and (iii) to request portability of it

Subject to the conditions prescribed in applicable laws, you have the right (i) to object, on grounds relating to your particular situation, to the processing of your personal data which is based on our or a third party’s legitimate interests; and (ii) to object to processing of your personal data for direct marketing purposes.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

You can exercise these rights by contacting us.

Amendments to this privacy policy

We reserve the right to revise this policy at any time by posting a revised privacy policy and, if we consider it necessary, we will notify you of material changes.

Indemnity

The Users agree to defend, indemnify and hold harmless Goldady, its officers, subsidiaries, affiliates, successors, assigns, directors, officers, agents, service providers, suppliers and employees, from and against any and all claims, damages, obligations, losses, liabilities, costs or debt, and expenses (including but not limited to attorneys' fees) arising from: (i) User's use of and access to the Site and/or the Service; (ii) User's violation of any of the Site's terms and conditions; (iii) User's violation of any third party right, including without limitation any copyright, trademark, and other intellectual property rights, trade secret or other property, or privacy right; or (iv) any claim that the User's content caused damage to a third party. This defense and indemnification obligation will survive termination, modification or expiration of this Privacy Policy and the User's use of the service and the Site.

Liability

In the event of a claim, the Users may under no circumstances engage Goldady's liability, unless due to the gross negligence of Goldady. In addition to the cases provided for in this Privacy Policy and the liability of Goldady is excluded in the following cases:

Unlawful use of the Site and/or the service by the User,
Abnormal function of the Site and/or the service,
Fraudulent intrusion by a third party into the Site and/or the Service,

How can you contact us?

If you have any questions about this privacy policy or would like to make any requests as described in this privacy policy, please contact us using the details on our website www.goldady.com.