### 1. Introduction

Snaxa Internet Service LLC ("SocialMart," "we," "us," or "our") firmly believes in protecting the privacy of our valued users ("you," "your"). This Privacy Policy governs how your personal information is collected, used, and shared when you interact with our online marketplace platform www.socialmart.co (the "Platform").

### 2. Purpose of this Policy

- To provide transparency regarding our data practices.
- To detail the rights you have over your personal data.
- To ensure compliance with applicable privacy laws, including the General Data Protection Regulation UAE data protection laws, and relevant legislation within GCC countries.

### 3. Scope of this Policy

This Privacy Policy covers all interactions with our Platform, specifically:

- Browsing our marketplace
- Creating an account
- Purchasing or selling products
- Contacting customer support
- Subscribing to our marketing communications

### 4. Data Collection

#### 4.1 Types of Data Collected

We may collect the following categories of information:

- Personal Identifiers: Name, email address, phone number, billing and shipping addresses.
- Financial Information: Payment card details (note: All credit/debit cards details and personally identifiable information will NOT be stored, sold, shared, rented or leased to any third parties).
- Usage Information: IP address, device type, browser type, pages viewed, items purchased, search terms, interactions on our Platform.
- Social Media Data: Information you allow us to access if you connect social media accounts to our Platform.

#### 4.2 Methods of Collection

We collect this data through the following methods:

- Directly from You: When you provide information through forms, account creation, order placement, or communication with us.
- Automatic Collection: Through cookies and similar tracking technologies that monitor your Platform usage.
- Third-Party Sources: Potentially from payment providers, shipping partners, and analytics services – to be detailed as your platform operations are finalized.

#### 4.3 Purpose of Collection

We collect this data for the following purposes:

- To provide and operate the Platform.
- To process and fulfill your orders.
- To offer customer support and personalization.
- To improve the Platform and develop new features based on analytics.
- To communicate with you about products, services, or promotions (only with your consent).
- To protect the Platform's security and integrity.
- To comply with legal and regulatory obligations.

### 5. Data Use

#### 5.1 Internal Use

We use your data internally in the following ways:

- Order Processing and Fulfillment: To complete transactions and ship your orders.
- Customer Support: To provide assistance, troubleshoot issues, and handle inquiries.
- Platform Improvement: To analyze usage patterns, optimize the user experience, and develop new features and services.
- Marketing and Personalization (with consent): To send you offers, promotions, and relevant content based on your preferences and interactions with our Platform.
- Security and Fraud Prevention: To protect our Platform, users, and your data, as well as to detect and prevent fraudulent activity.

#### 5.2 External Sharing

We may share limited information with trusted third parties in certain circumstances:

- Payment Processors: To facilitate secure payment transactions.
- Shipping Carriers: To fulfill and deliver your orders.
- Analytics Services: To better understand platform usage and trends (data is typically anonymized or aggregated).
- Marketing Partners (with consent): To collaborate on promotions and campaigns.
- Legal Authorities: If legally required by law enforcement, court orders, or other regulatory processes.

We only share the minimum necessary information and will have agreements in place to protect your data.

### 6. Data Security

We take the security of your data seriously and implement appropriate technical and organizational measures to protect it, including:

- Encryption: Protecting sensitive data in transit and at rest.
- Access Controls: Limiting access to your data on a need-to-know basis.
- Firewalls and Security Monitoring: Detecting and preventing unauthorized access attempts.
- Regular Security Updates: Maintaining up-to-date software and systems.

While we take all reasonable security precautions, no data transmission or storage system can be guaranteed as 100% secure.

### 7. User Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

- Right to Access: To obtain a copy of the personal information we hold about you.
- Right to Rectification: To correct inaccurate or incomplete information.
- Right to Erasure (“Right to be Forgotten”): To request deletion of your data in certain circumstances.
- Right to Restrict Processing: To limit how we use your data.
- Right to Data Portability: To receive your data in a portable format to transfer it elsewhere.
- Right to Object: To object to certain processing activities, such as direct marketing.
- Right to Withdraw Consent: To withdraw consent at any time, where consent is the basis for processing.

### 8. International Data Transfers

Our platform operates across multiple countries within the UAE and GCC region. In some cases, your personal information may be transferred, processed, or stored outside your country of residence. We take steps to ensure that your data is protected in accordance with this Privacy Policy and applicable data protection laws, regardless of its location.

Mechanisms for Lawful Transfer: We utilize the following mechanisms to safeguard international data transfers:

- Adequacy Decisions: We may transfer data to countries that have been recognized as providing an adequate level of data protection by the relevant authorities.
- Standard Contractual Clauses: We establish legally binding contracts with third parties located outside the UAE/GCC that include standard data protection clauses approved by relevant authorities.
- Data Processing Agreements: We implement detailed agreements with all third parties who process your data on our behalf, ensuring they adhere to appropriate security and confidentiality measures.

### 9. Children's Privacy

Our Platform includes sections designed specifically for children under the age of 13 (or a different age as legally required). We take children's privacy seriously and comply with the Children's Online Privacy Protection Act (COPPA) in the United States and similar regulations in other jurisdictions.

Parental Consent: Before collecting personal information from children, we obtain verifiable parental consent through methods that comply with applicable laws.

Limiting Data Collection: We only collect the minimal amount of personal information from children necessary to provide the relevant Platform features and services.

Additional Protections: We implement additional safeguards for children's data, such as restricting certain types of marketing and limiting behavioral advertising.

### 10. Cookies and Tracking

We use cookies and similar tracking technologies to personalize your experience and analyze how our Platform is used. For more detailed information, please refer to our separate Cookie Policy.

### 11. Changes to Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our data practices, legal requirements, or the services we provide. We will prominently display a notice on our Platform to inform you of any significant changes. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about how we are protecting your information. The effective date at the top of this Privacy Policy indicates when it was most recently revised.

### 12. Dispute Resolution

If you have any concerns about our privacy practices, please contact us using the following details:

- Email: help@socialmart.co
- Contact Form: Go to contact form

We will address your concerns and endeavor to resolve any complaints in a timely and fair manner. If a dispute cannot be resolved through our internal process, you may have options for further recourse, such as the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

### 13. Limitation of Liability

Disclaimer: Our Platform and services are provided on an "as is" and "as available" basis. We make no representations or warranties of any kind, express or implied, as to the operation of the Platform or the information, content, or materials included therein. We disclaim all warranties, including implied warranties of merchantability, fitness for a particular purpose, and non-infringement.

Limitation of Damages: To the fullest extent permitted by law, we shall not be liable for any direct, indirect, incidental, special, or consequential damages arising from your use of the Platform. This limitation applies even if we have been advised of the possibility of such damages.

Exceptions: This limitation of liability may not apply in jurisdictions that do not allow for the exclusion or limitation of certain damages.

### 14. Governing Law and Jurisdiction

This Privacy Policy and any disputes arising from or related to the use of our Platform shall be governed by and construed in accordance with the laws of the United Arab Emirates. Any disputes shall be resolved exclusively through the courts of UAE.

### 15. Contact Information

If you have any questions or concerns about our privacy practices or this Privacy Policy, please contact us at:

- Email: help@socialmart.co

### 16. Additional Provisions for UAE Residents

There are relevant regulations and guidelines issued by the Telecommunications Regulatory Authority (TRA) and the Dubai Electronic Security Center (DESC) that address data privacy. We are committed to complying with these guidelines and best practices for user privacy protection.

Transparency and Notice: We strive to provide clear and transparent information about our data collection practices through this Privacy Policy and any additional notices within the Platform.

Consent: We will obtain your consent for the collection and use of your personal information, except in limited circumstances permitted by UAE regulations (e.g., legal obligations).

Data Security: We implement appropriate technical and organizational safeguards to protect your personal information from unauthorized access, disclosure, alteration, or destruction.

Your Rights: While a comprehensive data protection law is not yet in effect, you may still have certain rights regarding your personal information. These rights may include the ability to access, rectify, or request deletion of your data, subject to applicable legal exceptions.

We will update this section to reflect any future developments in UAE data privacy laws.

### 17. Additional Provisions for EEA and UK Residents

Data Controller: Snaxa Internet Service LLC is the Data Controller responsible for processing your personal information.

Legal Basis for Processing: We process your personal data based on the following legal grounds:

- Consent: For specific purposes, such as marketing communications.
- Contractual Necessity: To fulfill orders and provide you with our services.
- Legitimate Interests: To improve our Platform, ensure security, and prevent fraud (where these interests do not override your fundamental rights).
- Legal Obligations: To comply with tax, accounting, or other legal requirements.

Your Rights under GDPR: In addition to the rights outlined earlier in this policy, you may also have the following rights under the General Data Protection Regulation (GDPR):

- Right to Object to Certain Processing: Including direct marketing.
- Right to Restriction of Processing: In certain circumstances.
- Right to Lodge a Complaint: With the relevant data protection authority in your jurisdiction.

### 18. Additional Provisions for Other GCC Countries

While comprehensive federal data privacy laws are yet to be standardized across the Gulf Cooperation Council (GCC) region, individual member states have adopted their own frameworks and regulations. SocialMart operates in several GCC countries, each with unique data protection requirements. Below is an overview of the data privacy considerations relevant to these jurisdictions:

#### Kingdom of Saudi Arabia (KSA):

The Saudi Arabia Personal Data Protection Law (PDPL) came into effect in March 2022.

Compliance Requirements: We are committed to complying with the PDPL's mandates concerning data collection, processing, storage, and transfer. This includes securing user consent for specific data uses, implementing robust security measures, and ensuring the protection of user rights.

User Rights under PDPL: Rights for users in KSA include accessing, rectifying, erasing, and restricting the processing of their personal data. These rights ensure users have significant control over their personal information.

#### Kingdom of Bahrain:

Bahrain's data protection framework is outlined in its 2008 Electronic Transactions Law.

Data Processing Principles: We adhere to principles of fairness, transparency, and purpose limitation in our data processing activities.

Data Security Measures: The law mandates appropriate technical and organizational safeguards to protect user data, which we rigorously implement.

#### Qatar:

Qatar enacted its Data Protection Law in 2016, reflecting principles similar to those in the GDPR.

Compliance Requirements: We comply with Qatar's Data Protection Law by ensuring lawful processing of personal data, securing explicit consent for certain uses, and protecting the rights of data subjects.

User Rights: These include the right to access, correct, and delete their data, alongside protections against unauthorized data processing.

#### Oman:

Oman introduced its Electronic Transactions Law, which includes several provisions on data protection.

Data Handling Practices: We ensure that data handling practices comply with Omani laws by emphasizing data security and limiting data processing to explicitly stated purposes.

#### Kuwait:

Kuwait continues to rely on its general laws related to privacy and information security, with specific provisions that impact electronic transactions.

Data Protection Measures: We adhere to best practices in data security and privacy to align with Kuwaiti regulations on data protection and electronic transactions.

### 19. Commitment to Transparency and Updates

At SocialMart, our commitment to maintaining your trust is paramount. We believe in providing clear, accessible information about how we handle your personal data. Our Privacy Policy is designed to give you comprehensive insights into our data practices, ensuring you understand your rights and the measures we take to protect your privacy.

Continuous Updates: We continuously review our Privacy Policy to adapt to new technologies, business practices, and regulatory requirements. The dynamic nature of our services and the digital landscape means changes may occur, and we are committed to keeping you informed of these changes.

Notice of Changes: Any significant updates to our Privacy Policy will be communicated through our Platform with clear notice. Minor changes that do not materially affect your rights will be updated directly in this document, with the effective date at the top indicating the most recent revision.

Feedback and Questions: We value your feedback and encourage you to reach out with any questions or concerns about our privacy practices. Your input helps us improve and ensures that our practices align with your expectations.

### Contact Us:

For further information or to provide feedback about our Privacy Policy, please contact us via:

- Email: help@socialmart.co
- Contact Form: Go to contact form

#### ready to get started?

Download App
Download App