Abjadiyat Academy Privacy Policy
We, at Alef Education, are committed to protecting your personal data and respecting
your privacy. This policy (together with our end-user terms of service)applies to your
use of:
●the Abjadiyat Academy application and online platform (together the Services
Sites); and
●any of the services accessible through the Services Sites (Services) (unless the
end-user terms of service state that a separate privacy policy applies to a
particular Service, in which case that privacy policy only applies. This policy sets
out the basis on which any personal data we collect from you, or that you provide
to us, will be processed by us.
If you are under 18 or the legal age of majority in your jurisdiction, your parent or legal
guardian must provide Consent for you to download the Apps and use the Services in
accordance with this policy. We advise parents and legal guardians who permit their
children tousethe Services to communicate with their children about their safety
online.
Please read the following carefully to understand our practices regarding your personal
data and how we will treat it.
This policy is provided in a layered format so you can click through to the specific areas
set out below. Alternatively, you can download a pdf version of the policy here. A
child-friendly version of this policy is also available here.
This privacy policy is provided in a layered format so you can click through to the
specific areas set out below:
Important information and who we are
How is your personal data collected
How we use your personal data
Disclosures of your personal data
International transfers
Data security
Data retention
Your legal rights
Glossary
Important information and who we are
Alef Education Consultancy LLC is the controller and is responsible for your personal
data (collectively referred to as "Company", "we", "us" or "our" in this policy) and is
defined as a controller under some data protection laws (such as the General Data
Protection Regulation 2016/679 (GDPR) and the UAE Federal Decree-Law No. (45) of
2021 on Personal Data Protection).
Contact details
Legal Name of
Entity
Commercial
License
Number
Email Address
Postal Address
Alef Education
Consultancy LLC
CN-2209313
Privacy@alefeducation.com
PO Box
769719, Abu
Dhabi, United
Arab Emirates
Changes to this privacy policy
We keep our privacy policy up to date and under regular review.
This version was last updated on 02/10/2022. It may change and if it does, these
changes will be posted on this page and, where appropriate, we will notify you when you
subsequently log onto one of the Services Sites. The new policy may be displayed
on-screen and you may be required to read and accept the changes to continue your use
of the Services Sites or the Services.
It is important that the personal data we hold about you is accurate and current. Please
keep us informed if your personal data changes during your use of the Services.
Third party links
Our Services Sites may, from time to time, contain links to and from the websites of our
partner networks, advertisers, and affiliates. Please note that these websites and any
services that may be accessible through them have their own privacy policies and that
we do not accept any responsibility or liability for these policies or for any personal data
that may be collected through these websites or services. Please check these policies
before you submit any personal data to these websites or use these services.
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as
follows:
●Contact Data.
●Content Data.
●Device Data.
●Financial Data.
●Identity Data.
●Location Data.
●Marketing and Communications Data.
●Profile Data.
●Transaction Data.
●Usage Data.
We explain these categories of data here.
We also collect, use and share Aggregated Data such as statistical or demographic data
for any purpose. Aggregated Data could be derived from your personal data but is not
considered personal data in law as this data will not directly or indirectly reveal your
identity. For example, we may aggregate your Usage Data to calculate the percentage of
users accessing a specific App feature. However, if we combine or connect Aggregated
Data with your personal data so that it can directly or indirectly identify you, we treat the
combined data as personal data which will be used in accordance with this privacy
policy.
We do not collect any Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your health,
and genetic and biometric data). Nor do we collect any information about criminal
convictions and offences.
How is your personal data collected?
●Information you give us.
This is information (including Identity Data, Contact Data, and Communications Data)
you Consent to giving us about you by filling in forms on the Services Sites, or by
corresponding with us (for example, by email or other means of communication). It
includes information you provide:
o when you register to use the Services Sites, download, or subscribe to any
of our Services, search for a Service Site or Service, make a purchase
within one of our Services Sites or enter a competition, promotion or
survey; or
o when you send us any communications regarding our Services or any of
our Services Sites. If you contact us, we will keep a record of that
correspondence.
●Information we collect about you and your device.
Each time you visit one of our Services Sites we will automatically collect personal data
including Device, Content and Usage Data. We collect this data using cookies and other
similar technologies.
●Information we receive from other sources including third parties and publicly
available sources.
We will receive personal data about you from various third parties and public sources as
set out below:
o Device Data from the following parties:
▪analytics providers;
▪advertising networks; and
▪search information providers.
o Contact, Financial and Transaction Data from providers of technical,
payment and delivery services.
●Location Data.
We also use GPS technology to determine your current location. Some of our
location-enabled Services require your personal data for the feature to work. If you wish
to use the particular feature, you will be asked to Consent to your data being used for
this purpose. You can withdraw your Consent at any time by disabling Location Data in
your settings.
●Unique application numbers.
When you want to install or uninstall a Service Site containing a unique application
number or when such a Service Site searches for automatic updates, that number and
information about your installation, for example, the type of operating system, may be
sent to us.
●Cookies
We use cookies and/or other tracking technologies to distinguish you from other users
of the Services Sites and the distribution platform (Appstore)and to remember your
preferences. This helps us to provide you with a good experience when you use our
Services Sites and also allows us to improve the Services Sites. For detailed information
on the cookies we use, the purposes for which we use them and how you can exercise
your choices regarding our use of your cookies, please contact us.
How we use your personal data.
We will only use your personal data where the law allows us to do so. This includes:
●Where you have Consented before the processing;
●Where we need to perform a contract we are subject to;
●If permitted by law, where it is necessary for our Legitimate Interests (or those of
a third party) and your interests and fundamental rights do not override those
interests; and
●Where we need to comply with legal or regulatory obligations.
We will only send you direct marketing communications by email, phone, SMS or
through the Services Sites if we have your consent. You have the right to withdraw that
Consent at any time by contacting us.
We will get your express opt-in Consent before we share your personal data with any
third party for marketing purposes.
Purposes for which we will use your personal data
Purpose/activity
Type of data
Lawful basis for
processing
To install the App and
register you as a new
App user
Identity
Contact
Financial
Device
Your Consent
To process in-App
purchases and deliver
Services including
managing payments and
collecting money owed to
us
Identity
Contact
Financial
Transaction
Device
Marketing and
Communications
Location
Your Consent
Performance of Contract
with you
Necessary for our
Legitimate Interests (to
recover debts due to us)
To manage our
relationship with you
including notifying you of
changes to the App or
any Services
Identity
Contact
Financial
Profile
Marketing and
Communications
Your Consent
Performance of Contract
with you
Necessary for our
Legitimate Interests (to
keep records updated
and to analyse how
customers use our
products/ Services)
Necessary to comply
with legal obligations (to
inform you of any
changes to our terms and
conditions)
To enable you to
participate in a prize
draw, competition or
complete a survey
Identity
Contact
Device
Profile
Marketing and
Communications
Your Consent
Performance of Contract
with you
Necessary for our
Legitimate Interests (to
analyse how customers
use our
products/Services and to
develop them and grow
our business)
To administer and
protect our business and
this App including
troubleshooting, data
analysis and system
testing
Identity
Contact
Device
Necessary for our
Legitimate Interests (for
running our business,
provision of
administration and IT
services, network
security)
To deliver content and
advertisements to you
To make
recommendations to you
about goods or services
which may interest you
To measure and analyse
the effectiveness of the
advertising we serve you
To monitor trends so we
can improve the App
Identity
Contact
Device
Content
Profile
Usage
Marketing and
Communications
Location
Your Consent
Necessary for our
Legitimate Interests (to
develop our
products/Services and
grow our business)
Disclosures of your personal data
When you Consent to providing us with your personal data, you also Consent to share
your personal data with the various third parties set out below:
1. Internal third parties. Other companies within our corporate group acting as joint
controllers or processors.
2. Approved external processors. We may share personal data with service providers
to help enable us to provide our products and services to you. Our approved
sub-processor s are mentioned in the list below:
Name of Processor
Location
Services
Amazon Web Services
(AWS)
Singapore
AWS provides Alef
Education hosted cloud
services for the processing
of user data
Google Data Studio
US
Provides data reporting
functions
Stripe Payments Europe ltd
Ireland
Payment processing
services
Zoom
US
Video conferencing
services
We require all third parties to respect the security of personal data it shares and to treat
it in accordance with the law. We do not allow its third-party service providers to use
personal data for their own purposes and only permits them to process your personal
data for specified purposes in accordance with this Privacy Policy and our instructions.
3. Change in management Third parties to whom we may choose to sell, transfer or
merge parts of our business or our assets. Alternatively, we may seek to acquire
other businesses or merge with them. If a change happens to our business, then the
new owners may use your personal data in the same way as set out in this privacy
policy.
4. Compliance Purposes We may also disclose your personal data to a third party to
comply with applicable laws or regulations, or a valid legal request. If we are going to
release personal data in this instance, we will use reasonable attempts to provide
you with notice in advance by email, unless we are prohibited from doing so by law
or otherwise where it is impracticable to do so in the circumstances.
International transfers
Our team are located in the United Arab Emirates but the data will be hosted on servers
in Singapore. Notwithstanding the foregoing, when using the Services and interacting
with us, your personal data may be transferred outside of your home country and may
be stored in and accessed from various countries in compliance with applicable laws.
Some of Alef Education external third party service providers are also based in
jurisdictions outside of your home country and therefore the processing of your
personal data may involve a transfer of data outside of your home country.
Whenever we transfer personal data to another jurisdiction, we ensure a similar degree
of protection is afforded to it by ensuring at least one of the following safeguards is
implemented:
●We will only transfer your personal data to countries that have been deemed to
provide an adequate level of protection for personal data.
●Where we use certain service providers, we may use specific contracts which
give personal data the same protection.
Data security
All information you provide to us is stored on our secure servers. Any payment
transactions are carried out with our third-party payment processing service provider
directly and will be encrypted with AES-256. Decryption keys are stored on separate
machines. Our third-party payment processing service provider has been audited by a
PCI-certified auditor and is certified toPCI Service Provider Level 1 which is the most
stringent level of certification available in the payments industry.
Where we have given you (or where you have chosen) a password that enables you to
access certain parts of the Services Sites, you are responsible for keeping this
password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security
features (such as encryption in transit and at rest) to try to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way.
However, no security measures are perfect and we cannot ensure or warrant the
security of any or all of the information that is shared by you. If any personal data is
compromised as a result of a breach of security, we will take steps to investigate the
situation and may notify you of the security incident in accordance with applicable laws
and regulations.
Certain Services include social networking, chat room or forum features. Ensure when
using these features that you do not submit any personal data that you do not want to
be seen, collected or used by other users.
For security purposes, we may reach out to you to verify your information.
Data retention
In the event that you delete your account with us we will also delete your personal data
within 60 days following the deletion of your account. During this period, you may
reactivate your account without loss of data.
Where we are required to do so by law, we will retain basic information about you after
the account is deleted. In limited circumstances we may also retain your personal data
for a longer period in the event of a complaint or if we reasonably believe there is a
prospect of litigation in respect to our relationship with you.
In some circumstances you can ask us to delete your data.
In some circumstances we will anonymise your personal data (so that it can no longer
be associated with you) for research or statistical purposes, in which case we may use
this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, data protection laws may give you rights in relation to
your personal data. These rights differ based upon local data protection laws of your
country, state, or territory, but these rights may include one or more of the following:
●To ask if we hold personal data about you and request copies of such personal
data and information about how it is processed (also called anaccess request);
●To request that inaccurate personal data is corrected (also called a rectification
request);
●To request deletion of personal data that is no longer necessary for the purposes
of the processing, processed based on withdrawn Consent, or processed other
than in compliance with applicable legal requirements;
●To request that we restrict the processing of your personal data where the
processing is inappropriate or not as anticipated;
●To object to the processing of your personal data;
●To request portability of your personal data (which does not include information
derived from the collected personal data), where the processing of such personal
data is based on Consent or a contract with you and is carried out by automated
means; or
●To withdraw consent from processing your personal data where we are relying on
consent to process your personal data. However, this will not affect the
lawfulness of any processing carried out before you withdraw your consent. If
you withdraw your consent, we may not be able to provide certain products or
services to you. We will advise you if this is the case at the time you withdraw
your consent.
You also have the right to ask us not to continue to process your personal data for
marketing purposes.
Please consult your local data protection laws to determine what rights may be
available to you. If you wish to exercise any of the rights that are provided to you by law,
please use the individual rights portal. For any other query, please contact us
atprivacy@alefeducation.com. Alef Education endeavours to comply with these
requests within one calendar month of following the verification of your identity,
however in certain circumstances it may take longer if your request is complex or
excessive. If this is the case, we will let you know.
Glossary
Consent means processing your personal data where you have signified your agreement
by a statement or clear opt-in to processing for a specific purpose. Consent will only be
valid if it is a freely given, specific, informed and unambiguous indication of what you
want. You can withdraw your Consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our
business to enable us to give you the best service/product and the best and most
secure experience. We make sure we consider and balance any potential impact on you
(both positive and negative) and your rights before we process your personal data for
our legitimate interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your Consent or are
otherwise required or permitted to by law). You can obtain further information about
how we assess our legitimate interests against any potential impact on you in respect
of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request
before entering into such a contract.
Category of Data
Definition
Contact Data
Billing address, email address and phone
number
Content Data
includes information stored on your
Device, including friends' lists, login
information, photos, videos or other
digital content and check-ins.
Device Data
includes the type of mobile device you
use, a unique device identifier (for
example, your device's IMEI number, the
MAC address of the device's wireless
network interface, or the mobile phone
number used by the device), mobile
network information, your mobile
operating system, the type of mobile
browser you use and time zone setting.
Financial Data
Bank account and payment card details.
Identity Data
First name, last name, gender, username
or similar identifier, title, date of birth and,
optionally, your school name, grade (if
applicable).
Location Data
Includes your current location disclosed
by GPS technology.
Profile Data
includes your username and password,
purchase history, preferences, interests,
interactions, progression, assessment
test results, feedback and survey
responses.
Usage Data
includes details of your use of any of our
Services Sites including, but not limited
to, the resources that you access, traffic
data and other communication data.
Marketing and Communications Data
includes your preferences in receiving
marketing from us and our third parties
and your communication preference.
Transaction Data
includes details about payments to and
from you and details of Services
purchases
