I. INTRODUCTION
Welcome to the NASMAAKUM Platform. We hope you enjoy the experience! It is important that you, the Customer, read this Privacy Policy (“Policy”) before using the Platform and/or any associated services provided by NASMAAKUM. If you do not understand or are unsure about any aspect of this Policy, please contact us to clarify the matter for you. By accessing or authorizing others to use the Platform, you are agreeing to be bound by the entirety of this Policy.
PLEASE READ THIS POLICY CAREFULLY BEFORE BROWSING THE PLATFORM. USING THIS PLATFORM INDICATES THAT YOU HAVE BOTH READ AND ACCEPT THIS POLICY. YOU CANNOT USE THIS PLATFORM IF YOU DO NOT ACCEPT THIS POLICY.
II. DEFINITIONS
‘Invita’ (“Us” or “Our” or “We”) shall mean Invita Company B.S.C. Any reference to NASMAAKUM in this Policy shall be a reference to Invita. ‘Platform’ shall mean Invita’s NASMAAKUM application. ‘Customer’ (‘You’ and ‘Your’) shall mean any authorized user of the Platform. ‘Interpreter’ or ‘Linguist’ means a person that uses the Platform to engage with a Customer for the purpose of providing language assistance and culture-oriented advice. ‘Devices’ shall mean your mobile device, PC or tablet used to access the Platform
III. DATA PROTECTION AND PRIVACY POLICY
A) NASMAAKUM is committed to maintaining the confidentiality, integrity, and security of personal and sensitive information collected from Customers, in accordance to the applicable laws. Accordingly, the Customer provides the acknowledgment described in this Section III as a confirmation of his/her understanding of NASMAAKUM’s use of Personal Data, and to give his/her explicit consent to the processing of his/her Personal Data by NASMAAKUM in line with the applicable Data Protection Laws.
B) For the purposes of all clauses under this Section III, the terms (“Processing”) and (“Personal Data” or “Data”) shall be defined as per the definitions set out under the Bahrain Law No. (30) of 2018 on the issuance of the Personal Data Protection Law and any amendments thereto.
C) The Customer hereby confirms that the Information and Data provided to NASMAAKUM is complete, correct and accurate. The Customer undertakes to inform NASMAAKUM in writing of any changes that may occur to the provided Information and Data and to update the same at any time when requested to do so by NASMAAKUM.
D) The Customer understands and acknowledges that NASMAAKUM may retain and process the Customer’s Personal Data for the following purposes:
• Improving the Platform and any related services
• Benefiting from products and services offered by NASMAAKUM
• The facilitation and execution of a contract or transaction to which the Customer is a party
• Audit and quality control
• Regulatory reporting
• Credit and tax reporting
• Compliance with the laws and regulations;
• Marketing of products and services;
• Data analytics
• Record keeping purposes
E) The Customer acknowledges that NASMAAKUM may share the Customer’s Data with any third parties in Bahrain or abroad if is authorized to do so under applicable Data Protection Laws, including our subsidiaries, affiliates, associates and other investee companies, regulatory authorities, professional service providers, external auditors, data processors, ancillary service providers, contractors, vendors, cloud service providers, and any other third parties as and when needed for the purposes mentioned above; or if NASMAAKUM are legally obliged to share this Data under the applicable laws and regulations. When required, NASMAAKUM has implemented adequate measures for providing an appropriate level of security including the necessary agreements in place to protect the sharing of the Customer’s Personal Data with a third party.
F) By agreeing to this Policy, the Customer hereby indicates their free will and full capacity in doing so after having read and understood the above. The Customer also give their consent to Us to collect, retain, process and share their Personal Data in accordance with the purposes stipulated here above. This consent shall apply to all products and services that may be provided by NASMAAKUM under the Platform, irrespective of product or service type.
IV. INFORMATION WE COLLECT
A) We collect Personal Data directly from individuals, from third parties, and automatically through the use of our Platform and may combine the information We collect from these various sources:
• Account and Registration Information: In order to use Our Platform and services, such as to see a home screen, search for or request a Linguist, or to sign up as a Linguist, You must register an account with Us and provide Us with Personal Data. We collect this information (including Personal Data) about You directly from You, including Your name, gender, email address, cell phone number, and Your native language. If You are a Linguist We also ask You about any languages You speak, proficiency levels, countries You have lived in, the time zone You are usually located in, and payment information (e.g. Your PayPal email address). For the purpose of providing more personalized and enhanced services, We may also ask or allow You to submit additional, optional account information, such as a nickname, profile picture, the city You are located in, areas of expertise and domain knowledge, and other voluntary profile information. We may also allow you to sign into Our Platform using third-party accounts, such as through Your Google or Facebook accounts. When You log in through these third-party accounts, You must grant Us permission to access and use certain information from these accounts, including Your name, email address, and certain profile information.
• User Content: We collect information regarding the text, image, audio and video files You share with other NASMAAKUM users, or any use of future chat functions to chat with other users on Our Sites or Platform (for example, when You upload a profile picture, request interpretation/translation services, leave comments and ratings). When You submit content, We maintain a copy of this content. We may also collect certain information metadata associated with Your content (e.g., location, date/time stamp, Device type).
• Your Location: Our Platform may access and collect Your geolocation information, and Our Platform may also track and collect Your location information in order to improve Our Platform and services by connecting You with the right Linguists in Your area who can provide a more stable call connection with You and be better suited to respond to Your request. You can enable or disable location services when You use Our Platform at any time by way of Your Device settings.
B) We may also collect information about You from third parties and affiliates, which We append to the information We have collected. Also, if You take advantage of a third party or affiliate offer through Platform, We may collect certain information from that third party about Your order or interaction with them, such as information You provide to Us or the third party, for example when filling out a questionnaire in relation to Our Platform or being referred to us by a partner affiliate.
C) We automatically collect the following information about You through Your use of Our Services including, but not limited to Your domain name; Your browser type and operating system; web pages You view; links You click; Your IP address; the length of time You visit Our Platform and/or use our services; and the referring URL, or the webpage that led You to our sites, as well as the following: access time, browser type, domain name, IP address, page views, and referring URL. We also may collect the following information about Your use of the Platform: mobile device ID; location and language information; Device name and model; operating system type, name, and version; Your activities within the Platform; and the length of time that You are logged into our Platform. We may combine this information with other information that We have collected about You, including, where applicable, Your user name, name, and other personal information.
V. LINKS TO THIRD PARTY APPS AND SITES
A) The Platform may from time to time provide links to third-party websites/apps. The Customer is not obligated to review any third-party websites/apps that the Customer is linked to from the Platform.
B) The Customer acknowledges that NASMAAKUM does not control any of the third-party websites/apps, and that NASMAAKUM are not responsible for any of the third-party websites/apps (or the products, services, or content available through any of them). Thus, NASMAAKUM does not endorse or make any representations about such third-party websites/apps, any information, software, products, services, or content found there or any results that may be obtained from using them.
C) If the Customer decides to access any of the third-party websites/apps linked from the Platform, the Customer does this entirely at their own risk and must follow the privacy policies and terms and conditions for those third-party websites/apps
VI. SUBMISSIONS
A) Certain areas of the Platform (e.g. customer ratings and review areas) may permit the Customer to submit feedback, information, data, text, software, messages, recordings, live video or audio, or other Content (each, a “User Submission”).
B) The Customer agrees that they are solely responsible for all of User Submissions and that any such User Submission is considered both non-confidential and non-proprietary. Further, NASMAAKUM do not guarantee that the Customer will be able to edit or delete any User Submission that they have submitted.
C) By submitting any User Submission, the Customer expressly warrants that:
• The Customer own all rights in the User Submission (including, without limitation, all rights to the reproduction and display of the User Submissions) or, alternatively, that the Customer has acquired all necessary rights in the User Submissions to enable the Customer to grant to NASMAAKUM the rights in the User Submissions as described in this Policy;
• The Customer has paid and will pay in full all license fees, clearance fees, and other financial obligations, of any kind, arising from any use or commercial exploitation of the User Submissions;
• The User Submissions do not infringe the copyright, trademark, patent, trade secret, or other intellectual property rights, privacy rights, or any other legal or moral rights of any third party;
• Any information contained in the User Submission is not known by the Customer to be false, inaccurate, or misleading;
• Your User Submission does not violate any law (including, but not limited to, those governing export control, consumer protection, unfair competition, anti-discrimination, or false advertising);
• The User Submission is not, and may not reasonably be considered to be, defamatory, libelous, hateful, racially, ethnically, religiously, or otherwise biased or offensive, unlawfully threatening, or unlawfully harassing to any individual, partnership, or corporation, vulgar, pornographic, obscene, or invasive of another’s privacy;
• The Customer was not and will not be compensated or granted any consideration by any third party for submitting the User Submission;
• The User Submission does not incorporate content from a third-party website, or addresses, email addresses, contact information, or phone numbers (other than the Customer’s content);
• The User Submission does not contain any viruses, worms, spyware, adware, or other potentially damaging programs or files;
• The User Submission does not contain any information that You consider confidential, proprietary, or personal; and
• The User Submission does not contain or constitute any unsolicited or unauthorized advertising, promotional content, junk mail, spam, chain letters, pyramid schemes, or any other form of solicitation.
D) By submitting a User Submission, the Customer grants NASMAAKUM with an irrevocable, perpetual, transferable, non-exclusive, fully-paid, worldwide, royalty-free license (sub-licensable through multiple tiers) to:
• Use, distribute, reproduce, modify, adapt, publish, translate, publicly perform, and publicly display the User Submissions (or any modification thereto), in whole or in part, in any format or medium now known or later developed;
• Use (and permit others to use) the User Submission in any manner and for any purpose (including, without limitation, commercial purposes) that NASMAAKUM deems appropriate in NASMAAKUM’s sole discretion (including, without limitation, to incorporate the User Submission or any modification thereto, in whole or in part, into any technology, product, or service);
• Display advertisements in connection with the User Submissions and to use the User Submissions for advertising and promotional purposes;
• Monitor the User Submissions as they occur, including monitoring conversations or videos between Customers and Linguists.
VII. PROPRIETARY RIGHTS
Nothing in this Policy shall convey to the Customer any proprietary or intellectual property rights, including without limitation, copyrights, trademarks, trade secrets, patents, moral rights, contract rights and licensing rights (the “Intellectual Property Rights”) belonging to NASMAAKUM, or be deemed to license the Customer to use any such Intellectual Property Rights of NASMAAKUM, except for the express limited purposes set forth herein. For the avoidance of doubt, “NASMAAKUM” and any other trademarks, names and logos on the Platform belongs to or are licensed by NASMAAKUM.