When you use our products and services, you entrust us with your information. We understand this is a significant responsibility, so we work diligently to protect your information in accordance with the GDPR and give you complete control over it. At the same time, we provide you with various services through this site, for which we retain full ownership rights and adhere to their terms of use.

Khutana E-Marketing recognizes the importance of privacy and the protection of personal data in our digital age. Therefore, we are committed to protecting the privacy of users of Khutana E-Marketing services while browsing or using our websites and services. This Privacy Policy and Terms of Use (“Privacy Policy” – “Terms of Use”) will explain how Khutana E-Marketing ensures the protection of personal data to a very high degree (such as any information relating to natural persons who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location information, an online identifier, or one or more factors specific to that natural person; hereinafter referred to as “Personal Data”). In addition, we also provide terms of use for services, products, resources, benefits, and the like.

Specifically, the Privacy Policy will explain: the following:

• Why do we collect and process your personal and general data protection? What is it?
• On what legal basis do we process your personal data?
• Who can access your personal data and the information collected;
• Where your personal data may be stored or transferred;
• How we protect the security of your personal data under the General Data Protection Regulation;
• How long we retain your personal data;
• How to access, update and delete your personal data;
• How we use cookies;
• How does the Privacy Policy apply to third party data processing such as Apple for personal data?

This Privacy Policy and Terms of Use apply to all services offered and provided by Khutana E-Marketing Company on its websites, digital applications, contests, and other digital properties (“Khutana E-Marketing Services”). You may also receive other special notices highlighting specific uses we may make of your personal data, as well as the ability to opt in or out of certain uses on a case-by-case basis, including new services or other services that may have their own privacy policies and terms of use.

Please note that in some countries, you must be 18 years of age or older to subscribe to Khutana E-Marketing services. The age of majority may be older than 18, in which case you must be of that age to subscribe. While individuals under the age of 18 may use Khutana E-Marketing services, they may do so only with the involvement, supervision, and consent of a parent or legal guardian.

Key definitions of Privacy Policy and Terms of Use:

“I,” “us,” or “we” refers to our online marketing services. “You,” or “User,” refers to the person(s) using Khutana E-Marketing services.

Privacy policy

Why do we collect and process your personal and general data protection? What is it?

We collect and process your personal data for the following purposes:

• To provide you with the services you request from us; to allow you to use online forms and surveys, including our online marketing services that do not require any form of registration; and to allow you to sign up for certain services, such as newsletters, information feeds, SMS updates, or to create an account, in which case we will ask you for personal data such as your name, email address, or telephone number.
• To allow you to share information; to allow you to take full advantage of the sharing features we offer, such as participating in viewer forums, social media and discussion boards, and interacting with second-screen co-viewing applications; to allow you to create a publicly viewable profile on our website, which may include, if you choose, your name and photo; and to combine your personal information we obtain through one service with information we collect from other services offered by our website to make it easier for you to share things with people you know.
• To maintain and improve our Services; to understand how you use Khutana E-Marketing services and implement other functions; and to develop new services and offers.
• To provide you with services tailored to your needs and interests; to provide you with personalized content such as relevant advertising and services; to allow us to get to know you better to provide you with more of the services you request, more offers, exclusive offers, information, competitions, and to give you a better user experience; and to reveal more complex things, such as which ads you might find most useful or which services and information are most relevant to you, giving you a better and more useful experience of our digital properties.
• To process payment transactions; to store transaction history; to ensure that you pay for our Services or quotes and the cost of the Services; and to comply with any legal or regulatory obligation in this regard.
• To communicate with you; to allow you to contact Khutana E-Marketing; to keep a record of our conversations; to help you resolve any issues you may have; to send you promotional offers and direct marketing; to inform you about our services such as providing you with information about upcoming programs or adding changes to our digital properties; and to contact you to compete and participate in various offers.
• To create and maintain a reliable and secure environment; to investigate, detect, prevent, or report fraud, misrepresentations, violations, security incidents, or other potentially prohibited or illegal activities; to protect our vendors, your rights, and the security and integrity of our Services; to enforce our Terms of Service or other agreements or policies; and to verify your identity.
• To comply with any applicable laws or regulations; to respond to lawful requests for information from the government or through legal process; to fulfill any other purpose disclosed to you in connection with our Services; and to contact you to resolve disputes and provide assistance with our Services.

On what legal basis do we process your personal data?

Depending on the type of data to be processed, we will process your personal data on one of the following bases:

• Your prior consent: For example, when we offer to register for our services and create an account, subscribe to our newsletters or marketing emails, or when we ask you to follow any relevant procedure that clearly allows you to either accept or refuse data processing, you have the right to withdraw your consent at any time. However, in some cases, choosing not to disclose your personal data or withdrawing your consent may limit your use of our services, features, or offerings. For example, you may not be able to access certain parts of our websites and respond to your inquiries without providing the relevant information.
• Contractual relationship: In such a case, the processing of your personal data is generally necessary for the performance or fulfilment of a contract; this means that if you do not want us to process your personal data in this context, we may refuse to enter into such a contract with you.
• Legitimate interest: In the sense of data protection law, for example, when monitoring or tracking devices are used to process personal data to detect and prevent online fraud and intrusion. For example, when you access and visit our websites, even without creating an account, and use the services offered by Khutana E-Marketing and/or Khutana E-Marketing’s digital properties, you acknowledge that we may legitimately process your data as described in our Privacy Policy and Terms of Use. If you do not agree to the Privacy Policy and Terms of Use, you may wish to stop viewing/using our websites.
• Legal obligations applicable to our activities from all parties, including the Ministry of Human Resources and Social Development.

Who can access your personal data and the information collected:

For the purposes described above, we will provide access to your personal data to our authorized e-marketing staff and members of Khutana E-Marketing team who need to know that information in order to process it for our benefit, and who are subject to strict contractual confidentiality obligations and may be disciplined and even terminated if they fail to comply with these obligations or the Privacy Policy.

In addition, we may need to transfer or allow an authorized third party to access your personal data, namely:

• Suppliers and service providers we engage to process personal data or perform Khutana E-Marketing services on our behalf (based on our instructions and in accordance with our Privacy Policy and other appropriate confidentiality and security measures);
• successors in ownership of the Company or our business (or in serious discussions about such a possibility with the new (potential) owners of the business or the Company); in this regard, if the ownership of the Company or all or a substantial part of our business changes, or if a corporate reorganization or other transaction or transfer of entities within Khutana E-Marketing plan takes place, you acknowledge and accept that we may need to transfer your personal data to the relevant third party (or advisors) as part of any process for the purpose of analyzing any proposed sale or reorganization to the new owner. We may also need to transfer your personal data to that reorganized entity or third party after the sale or reorganization of your personal data to use it for the same purposes as set out in this Privacy Policy;
• Representatives of our media agents;
• Legal advisors, witnesses, experts, judicial and quasi-judicial authorities in order to protect the Group from any harm to its rights, property or safety, to protect our users, the public and any third party as required or permitted by law, and to enforce the necessary terms of our Services, including investigating potential violations;
• Administrative or judicial authorities in order to satisfy the requirements of any applicable law, regulation, legal process or enforceable governmental request.
• We may also collect anonymous data publicly, with third parties, and with other authorized partners—such as advertising companies or connected sites. For example, we may share this information publicly to provide insights into the general use of our Services.

Where may your personal data be stored or transferred?

Khutana E-Marketing belongs to an international group with subsidiaries, partners, and contractors located in many countries around the world. For this reason, we may need to transfer your personal data to other countries, including outside the European Economic Area, and to countries where data protection laws may be weaker than those in your country. For example, we may process your personal data on a server located outside the country where you reside, and for this purpose, we may transfer your personal data outside your country of residence. In order to ensure an adequate and consistent level of protection for your personal data, we will continue to implement appropriate safeguards to protect your personal data. For more information, please contact us as described in the “How to Contact Us” section at the end of this Privacy Policy.

How do we protect the security of your personal data under the General Data Protection Regulation?

We maintain appropriate physical, electronic, technical, and organizational security measures, including governance models, to protect your personal data in accordance with data protection law from unauthorized access, use, alteration, disclosure, or destruction. Please note that no data transmission over the Internet or the website can be guaranteed to be uninterrupted. In addition, you must also take appropriate steps to protect your personal data, particularly by maintaining the confidentiality and security of your password.

If you know or suspect that your account credentials have been lost, stolen, misappropriated, or otherwise compromised, or if there has been any unauthorized use of your account, please contact us by following the instructions in the “How to Contact Us” section below at the end of this Privacy Policy. If we know or have reason to believe that your personal data has been compromised, we will promptly notify the affected users of the breach in accordance with applicable laws in this Privacy Policy.

How long do you keep your personal data?

We will retain your personal data for as long as your account is active, or as long as necessary for the purpose for which the data was originally collected. This retention period may be up to 10 years. Our retention periods are based on the needs of our business, and your information that is no longer required is permanently anonymized or destroyed. We aim to maintain our Services in a manner that protects information from accidental or malicious destruction. For this reason, after you delete information from our Services, we may not immediately delete any remaining copies from our active servers or remove the information from our backup systems. We may also retain your personal data for longer periods if necessary to comply with our legal obligations or to protect our legitimate interests.

How to access, update and delete your personal data?

Under the Data Protection Act you have the right to exercise the following rights:

• The right to access your personal data, in which case we may provide you with a copy of this data, if it is not directly available to you, for example within your personal account;
• The right to rectify your personal data if it is inaccurate or outdated. In this regard, it is important that the personal data we hold about you is accurate and up-to-date. Please inform us if any of your personal data changes during the period in which we hold your information.
• The right to withdraw consent, where processing is based on your prior consent and to withdraw your consent for all marketing;
• The right to object to the processing of your personal data, where the processing is based on our legitimate interests, as far as your situation allows;
• The right to erase your personal data;
• The right to restrict the processing of your personal data;
• The right to receive your personal data for transmission to a third party or to transfer your personal data to a third party of your choice if technically feasible;
• The right to lodge a complaint with a data protection authority if you consider that the processing of your personal data has violated data protection law.
• You may submit a request to us about these matters at any time as described in the “How to Contact Us” section at the end of this Privacy Policy page.

Please note the following:

• We may need to verify your identity before we can act on your request;
• Since the exercise of these rights is subject to certain legal conditions and restrictions, we may have to refuse your request if these conditions are not met or if there are legal restrictions;
• We may reject requests that are unreasonably repetitive, require technical effort (for example, developing a new system or fundamentally changing current practices), or pose a risk to the privacy of others.
• In any event, we will endeavor to deal with your request promptly within one month (subject to any extensions we may legally obtain). If we refuse your request, we will inform you of the reasons in accordance with the Privacy Policy.

How do we use cookies?

A cookie is a small piece of information that a web server sends to a web browser, allowing the server to collect information from your browser. Most browsers allow you to turn off cookies. If you want to learn how to do this, please see your browser’s help menu. However, some cookies are essential for us to provide you with the online marketing services you’ve requested, and turning off cookies will limit your use of our digital properties.

For example, we store and use cookies and similar technologies:

• To improve your user experience and ensure the overall quality of Khutana E-Marketing services;
• To identify you when you visit our digital websites;
• To track and study your browsing and navigation patterns on the Website, to create your demographic profile and to provide you with the service most suitable to your taste (more appropriate recommendations and offers relevant to what you like);
• To analyze content consumption habits (e.g., programs watched, content read, devices used, etc.) and to provide, personalize, measure, and improve our advertising and marketing;
• To provide appropriate content permitted in each geographic area based on the intellectual property rights licensed to us;
• To share some data to provide you with personalized advertising and send you marketing materials and newsletters.

We also share information about your use of our site with our social media, advertising, and analytics partners, who may combine it with other information you’ve provided to them or that they’ve collected from your use of their services. By using our online marketing services, you consent to our cookies. To learn more about how we use cookies, please contact us as described in the “How to Contact Us” section at the end of this Privacy Policy.

How to delete cache, cookies, history, and passwords from browsers such as Google Chrome

How does this Privacy Policy apply to third-party data processing by Apple of personal data?

Khutana E-Marketing services may be provided through and/or utilize features (such as voice controls) operated by third-party platforms, or contain links to sites operated by third parties whose policies regarding the processing of personal data may differ from ours.

For example:

• You may be able to access our e-marketing services through platforms such as gaming consoles, smart TVs, mobile devices, set-top boxes, and other internet-connected devices. Additionally, you may encounter third-party applications that interact with our e-marketing services. These third parties have separate and independent privacy and personal data policies.
• Our websites may contain links to other websites outside our control and not covered by this Privacy Policy. If you access other websites using the links provided, the operators of those websites may collect and use information from you in accordance with their own privacy policies, which may differ from ours.

We invite you to review these policies and terms if you wish to inquire about the processing of your personal data by a third party.

How to contact us?

If you have any further questions, please contact us at [email protected] or book a meeting.

How can I update the privacy policy?

We may update this Privacy Policy from time to time in response to legal, regulatory, or operational requirements. Any changes to this Privacy Policy will be posted on this page. Where such changes are material, we may provide you with specific notice of any such changes (including when they will take effect) in accordance with the law. We may not notify you of any updates or changes to this Privacy Policy. Where applicable (for example, if the changes require new data processing based on your prior consent), we will ensure that you are given the opportunity to accept these changes so you can continue using our Services or decline them—in which case you have the right to cancel your use of Khutana E-Marketing Services.

This Privacy Policy was updated on August 30, 2023.