The privacy of the User is important to New Age Marketing Company W.L.L. This Privacy Policy explains how and why New Age Marketing Company W.L.L. collects, uses, shares, transfers, and stores Personal Information, and pro vides information about the Users rights according to applicable Bahraini data protection laws.
This Privacy Policy governs Personal Information collected from the User who visits the website or uses the applications and Services of New Age Market ing Company W.L.L. (“Winasa Platform”). In this Privacy Policy, “the User” means the individual visiting or using the Winasa Platform or its Services.
New Age Marketing Company W.L.L. may revise this Privacy Policy from time to time by posting the amended terms on https://www.winasa.com/privacy policy.html. All amended terms automatically take effect immediately upon posting. The Users continued use after an updated Privacy Policy is posted means that the User accepts and consents to all its revisions.
For the purposes of this Privacy Policy, “Personal Information” means any data relating to an identified natural person, or one who can be identified directly or indirectly by way of linking data, using identifiers such as name, voice, picture, identification number, online identifier, geographic location, or one or more special features that express the physical, psychological, economic, cultural, or social identity of such person.
The User provides consent to New Age Marketing Company W.L.L.s process ing of Personal Information in accordance with this Privacy Policy.
For the purposes of applicable Bahraini data protection law, the “controller” processing the Users Personal Information is:
New Age Marketing Company W.L.L., a limited liability company registered in Manama, Bahrain with commercial license number xxxxxx and its registered office at P.O. Box xxxx, Manama, Bahrain.
The type of information New Age Marketing Company W.L.L. collects from the User is either personal to the User or is general in nature.
1. Personal Information: When the User registers on the Winasa Plat form as a member, updates information, purchases goods or Services, takes part in promotions, or sends emails to New Age Marketing Com pany W.L.L., the User provides information that New Age Marketing Company W.L.L. stores and processes. Such information may include the Users name, address, phone number, email address, credit and debit card information, purchase and transaction history, interests, im age, gender, age, location, nationality, and other similar information.
2. General Information: New Age Marketing Company W.L.L. also re ceives and/or automatically collects more general information from and about the User as a result of visits to, and use of, the Winasa Platform. This general information can include information such as the Users IP address, the date and time the User accesses the Winasa Platform, length of time spent on the Winasa Platform, browsing history (recorded by the text and graphics files that compose that page), the Internet ad dress of the website from which the User linked directly to the Winasa Platform, and other similar information.
The Personal Information New Age Marketing Company W.L.L. collects from the User in the course of rendering Services will be processed for the pur poses set out below.
1. New Age Marketing Company W.L.L. collects the Users credit/debit card information to allow the User to make purchases of goods/Services on the Winasa Platform. All credit/debit card details and Personal Infor mation will not be stored, sold, shared, rented, or leased to any third parties.
2. New Age Marketing Company W.L.L. collects the Users image and voice for the purposes of promoting the User as the winner of any Campaign Draws.
3. Most of the Winasa Platform can be used without giving New Age Mar keting Company W.L.L. any information. However, certain Services may involve the collection of information from the User. New Age Marketing Company W.L.L. uses this information to provide the User with a better service, and in particular to: keep internal records; improve products, Services, and the Winasa Platform; communicate with the User if the User has ordered, purchased, or participated in anything on the Winasa Platform; contact the User for market research purposes; and provide the User with information about new opportunities, promotions, special offers, and other information that New Age Marketing Company W.L.L. may feel is relevant to the User. If the User contacts New Age Marketing Company W.L.L. via the Winasa Platform or via email to the contacts set out on the Winasa Platform, New Age Marketing Company W.L.L. may keep a record of that correspondence.
4. New Age Marketing Company W.L.L. collects general information to help make the Winasa Platform more useful to users (including to assess content of interest to visitors), and for other purposes such as deter mining the Winasa Platforms technical design specifications and iden tifying system performance or problem areas, for tracking activity on the Winasa Platform, preparing reports, assessing trends, and other wise monitoring the way in which the Winasa Platform is being used, none of which would be in a way that personally identifies any users.
5. Some of the advertisements the User sees on the Winasa Platform are selected and delivered by third parties, such as ad networks, adver tising agencies, advertisers, and audience segment providers. These third parties may collect information about the User and the Users online activities, either on the Winasa Platform or on other websites, through cookies, web beacons, and other technologies in an effort to understand the Users interests and deliver advertisements that are tai lored to the Users interests. New Age Marketing Company W.L.L. does not have access to, or control over, the information these third parties may collect. The information practices of these third parties are not covered by this Privacy Policy, and the User should check the privacy policies of these third parties.
### **1.4 Non-Disclosure of Personal Information**
- The User agrees that New Age Marketing Company W.L.L. may share the Users Personal Information within its group entities and subsidiaries (together the “Company”). New Age Marketing Company W.L.L. will not share, sell, or rent the Users Personal Information in any manner to any third parties outside of the Company except when New Age Marketing Company W.L.L. has the Users consent under this Privacy Policy, or if required to do so by Bahraini law or any governing authority. For exam ple, New Age Marketing Company W.L.L. may share the Users Personal Information with third-party service providers, with brands for adver tising and marketing purposes, and with third parties for data storage purposes, and within the Company.
2. New Age Marketing Company W.L.L. may transfer the Personal Infor mation the User provides to another country. When New Age Market ing Company W.L.L. transfers the Users Personal Information to another country, it will take all reasonable steps to ensure that the Users Per sonal Information is protected in accordance with this Privacy Policy and applicable Bahraini data protection laws, including through using legally recognized data transfer mechanisms, such as appropriate stan dard contractual clauses where required.
### **1.5 Security**
- Keeping the Users Personal Information secure and preventing unau thorized access is of utmost priority to New Age Marketing Company W.L.L., and New Age Marketing Company W.L.L. takes all steps reason ably necessary to protect the Users Personal Information against any unauthorized access, use, alteration, disclosure, or destruction. Whilst New Age Marketing Company W.L.L. has put in place physical, elec tronic, and managerial procedures to secure and safeguard the Users Personal Information, New Age Marketing Company W.L.L. will not be held responsible for any unauthorized access by third parties, and New Age Marketing Company W.L.L. cannot guarantee that the Personal In formation provided by the User or that is transmitted via the Winasa Platform or by email is totally secure and safe.
- New Age Marketing Company W.L.L. encourages the User to keep any passwords used confidential and to be careful to avoid “phishing” scams where someone may send the User an electronic message that appears to be from New Age Marketing Company W.L.L. asking for Personal In formation. New Age Marketing Company W.L.L. will not request the Users ID or password through electronic messages.
- Like many websites, the Winasa Platform uses cookies, which are files that store information on the Users hard drive. Cookies allow the Winasa Platform to identify account holders, track new users, record session in formation, and generally optimize the Users experience. Most browsers accept cookies automatically, but if the User chooses, the User can disable cookies from their browser. For online advertising campaigns, cookies are automatically deleted after one (1) month.
- New Age Marketing Company W.L.L. recommends that the User leaves cookies “turned on” to enjoy a better experience on the Winasa Plat form. The User may occasionally get cookies from companies advertis ing on behalf of New Age Marketing Company W.L.L. or on behalf of the Company. New Age Marketing Company W.L.L. does not control these cookies, and these cookies are not subject to this Privacy Policy.
1. The Winasa Platform uses Google Analytics, a web analytics service of Google Inc. (“Google”). Google Analytics uses cookies and/or text files to analyze website traffic. Information generated by cookies with the Users details (including the Users IP address) is transferred to a Google server in the United States of America. Google processes this informa tion to evaluate the Users use of the Winasa Platform, compile reports about the Winasa Platforms activity on behalf of New Age Marketing Company W.L.L., and deliver other related services regarding website and Internet use. Google may also share this information with third parties insofar as this is necessary or if these third parties process the information on behalf of Google.
2. The User may disable cookies from their browser by adjusting browser settings. However, in this scenario, the User may not be able to make full use of all the functions available on the Winasa Platform. By using the Winasa Platform, the User agrees to Googles processing of the type of information discussed in this section in the manner contemplated in this Privacy Policy. New Age Marketing Company W.L.L., its respective suppliers, and any of its shareholders, the Company, and any of its and their officers, directors, managers, members, agents, and employees, are not liable for any direct, indirect, punitive, incidental, special, or consequential damages or loss (including, without limitation, incidental and consequential damages, lost profits, or damages resulting from lost data or business interruption) arising out of, or in any way connected with, the use of the type of information discussed in this section.
Facebook, Instagram, and Google tracking pixels are used on the Winasa Platform. This means that third parties may use cookies, web beacons, and similar technologies to collect or receive information from the Winasa Plat form and elsewhere on the internet and use that information to provide mea surement services and targeted advertisements. If the User wishes to opt out of the use of these tracking pixels, the User should adjust their browser settings.
1. The User may choose to receive or not receive marketing communications from New Age Marketing Company W.L.L. by indicating preferences.
2. The Users registration on the Winasa Platform is considered consent to receive marketing communications from New Age Marketing Company W.L.L. The User can unsubscribe from any marketing communications by sending an email to support@winasa.com, and failure to send such an email will be considered the Users continuing consent to receive marketing communications.
3. Any marketing by New Age Marketing Company W.L.L., or any third parties on its behalf, will be conducted in accordance with applicable Bahraini laws and include (where applicable) methods to allow the User to express preferences (including the possibility of being removed from advertising and marketing lists as set out above).
Where the processing of the Users Personal Information is subject to Bahraini data protection laws, the User has certain data subject rights. Depending on the applicable law, these include:
1.Access: The User has the right to request information about how New Age Marketing Company W.L.L. processes the Users Personal Informa tion.
2.Rectification: The User has the right to request the rectification of inaccurate Personal Information about the User and for any incomplete Personal Information about the User to be completed.
3.Transfer: The User has the right to request a transfer of the Users Personal Information.
4.Erasure: The User has the right to have the Users Personal Information erased.
5.Restriction: The User has the right to restrict the processing of the Users Personal Information in some cases.
6.Objection: The User has the right to object to processing in some cir cumstances, including for automated processing.
7.In addition to the above, the User has the right to withdraw consent to the processing of Personal Information at any time. Such withdrawal has no effect on any processing of Personal Information that has oc curred prior to the withdrawal of consent.
8.If the User has any questions about the type of Personal Information New Age Marketing Company W.L.L. holds or wishes to exercise any data subject rights, the User should send a written request to sup port@winasa.com.
New Age Marketing Company W.L.L. will retain the Users Personal Information for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by Bahraini law.