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PRIVACY POLICY

Syco Labs FZCO (“the Company”, “Us”, “We”, “Our”) understands that Your privacy is important to You and that You care about how Your personal data is used. We respect and value the privacy of everyone uses the Drunken Monkey App, website, and any associated products and services (“Our Service”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and Your rights under the law. 

Please read this Privacy Policy carefully and ensure that You understand it. By using Our Service, You are indicating that You have read, understood and consent to be bound by the terms of this Privacy Policy.

This Privacy Policy is effective from 1 August 2022.

  1. Information About Us

Our Service is owned and operated by Syco Labs FZCO, located at Dubai Silicon Oasis DDP, Building A1, Dubai, UAE (licence number 18967).

  1. What Does This Policy Cover?

This Privacy Policy applies only to Your use of Our Service. Our Service may contain links to other websites. Please note that We have no control over how Your data is collected, stored, or used by other websites and We advise You to check the privacy policies of any such websites before providing any data to them.

  1. What Is Personal Data?

Personal data Any data relating to: (a) an identified natural person or (b) a natural person who can be identified directly or indirectly by way of linking data, using identifiers such as name, voice, picture, ID number, online identifier, geographic location or special features that express the physical, psychological, economic, cultural or social identity of that person. It includes Sensitive Data and Biometric Data.

Personal data is, in simpler terms, any information about You that enables You to be identified. Personal data covers obvious information such as Your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

  1. What Are My Rights?

We will ensure We have appropriate policies, procedures and measures in place to secure Your rights, which include:

  • Right to obtain information – You have the right to be told about what aspects of – and how – Your Personal Data is being processed. Whilst there is no express requirement for businesses to use privacy notices, Your use could assist in securing compliance with this requirement amongst others.
  • Right to access – You have the right to obtain access to Your Personal Data.
  • Right to request Personal Data transfer – You have the right to request that Your Personal Data is moved from one business to another (e.g. if You decide to change service provider).
  • Right to correction or erasure – You have the right to require inaccurate information about themselves to be corrected and have the right to have Your Personal Data erased if it is no longer required for the purpose for which it was collected.
  • Right to restrict or stop processing – You may require Us to restrict or stop processing Your Personal Data in certain circumstances.
  • Right to file a complaint – You have the right to file a complaint with the UAE Data Office.
  • Right to withdraw consent – At any time You can withdraw consent You have given Us to process Your Personal Data.
  • Data security – We need to put in place appropriate technical and organisational measures to protect Personal Data.
  1. What Data Do We Collect?

Depending upon Your use of Our Service, We may collect and hold some or all of the personal (and non-personal) data, which may include:

  • Identity Data including name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data including address, email address, telephone number.
  • Financial Data such as bank account and payment card details and wallet address data.
  • Marketing and Communications Data, including Your preferences for receiving marketing from Us and third parties and Your communication preferences.
  • Profile Data including preferences and interests, login details, feedback and survey responses, purchase history.
  • Technical Data, including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices You use to interact with or access Our Service.
  • Third Party Data, including from third parties used by Us to provided Our Service to You, such as intercom transcripts related to Your engagement with Us and partners.
  1. How is Your personal data collected?

We use different methods to collect data from and about You including through:

  • Direct interactions: You may give us Your personal data by dealing with Our team member(s) in person, filling in forms or by corresponding with Us by post, phone, email or otherwise. This includes personal data You provide when You subscribe to become a member; create an account on Our Service; subscribe to Our publications; and newsletter or give us feedback or contact us.
  • Automated technologies or interactions: as You interact with Our service, We will automatically collect Technical Data about Your equipment, browsing actions and patterns.
  1. How Do We Use Your Personal Data?

We use the information We collect in various ways, including:

  • To perform a contract We are about to enter into or have entered into with You.
  • Where it is necessary for Our legitimate interests (or those of a third party), Your interests and fundamental rights do not override those interests.
  • Comply with a legal obligation.
  • To communicate with You, either directly or through one of Our partners, including for customer service, to provide You with updates and other information relating to the website, and for marketing and promotional purposes.
  • To send You emails and updates.
  • To provide, operate, and maintain Our Service.
  • To Improve, personalise, and expand Our Service.
  • To understand and analyse how You use Our Service.
  • To develop new products, services, features, and functionality.
  • To find and prevent fraud.
  • To log files.
  • To update subscribers regarding any changes to Our policies from time to time.
  • To make suggestions and recommendations about services and membership benefits that may be of interest to You.
  • To use data analytics to improve Our Service, services, marketing, member relationships and experiences.
  1. Change of purpose

We will only use Your personal data for the purposes for which We have collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

We may process Your personal data without Your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

If We need to use Your personal data for an unrelated purpose, We will notify You and We will explain the legal basis which allows us to do so.

  1. Data retention

We will only retain Your personal data for as long as reasonably necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may 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.

To determine the appropriate retention period for personal data, We consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of Your personal data, the purposes for which We process Your personal data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

  1. Cookies and Web Beacons

Our Service uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimise the users’ experience by customising Our web page content based on visitors’ browser type and/or other information.

  1. Google DoubleClick DART Cookie

Google is one of a third-party vendor on Our site. It also uses cookies, known as DART cookies, to serve ads to Our site visitors based upon their visit to www.website.com and other sites on the internet. However, visitors may choose to decline the use of DART cookies by visiting the Google ad and content network Privacy Policy at the following URL – https://policies.google.com/technologies/ads

  1. Marketing

We strive to provide You with choices regarding certain personal data uses, particularly around marketing and advertising. We may use Your personal to form a view on what We think You may want or need, or what may be of interest to You. This is how We decide which services may be relevant for You (We call this marketing). You may receive marketing communications from us if You have requested information from us or become a subscriber, in which case We may contact You based on Our legitimate interest. You will always be given the opportunity to opt out of Our marketing when We make contact.

In order for us to provide You the best user experience, We may share Your personal information with Our marketing partners for the purposes of targeting, modelling, and/or analytics as well as marketing and advertising. You may opt-out of sharing personal information with Our marketing partners, unless We have a legitimate interest to do so.

  1. Google

Google supports a healthy digital advertising ecosystem – one that’s trustworthy and transparent, and works for users, advertisers and publishers. If You would like to find out more, visit https://policies.google.com/technologies/ads.

  1. Advertising Partners Privacy Policies

Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Our Service, which are sent directly to users’ browser. They automatically receive Your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that You see on websites that You visit.

We have no access to or control over these cookies that are used by third-party advertisers.

  1. Our Advertising Partners

Some of advertisers on Our site may use cookies and web beacons. Each of Our advertising partners has their own Privacy Policy for their policies on user data. Please visit their websites for more information.

  1. Third-party links

Our Service may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about You. We do not control these third-party websites and are not responsible for their privacy statements. When You leave Our Service, We encourage You to read the privacy policy of every website You visit.

  1. Third Party Privacy Policies 

Our Privacy Policy does not apply to other advertisers or websites. Thus, We are advising You to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

You can choose to disable cookies through Your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.

  1. How and Where Do You Store or Transfer My Personal Data?

We store Your personal data in the UAE.  This means that We are fully compliant with the UAE Personal Data Protection Law.

We may store some or all of Your personal data in the UK. This means that it will be fully protected under UK Data Protection Legislation.

  1. How Can I Control My Personal Data?

In addition to Your rights under the Data Protection Legislation, when You submit personal data via Our Service, You may be given options to restrict Our use of Your personal data. In particular, We aim to give You strong controls on Our use of Your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which You may do by unsubscribing using the links provided in Our emails, at the point of providing Your details and by managing Your Account).

  1. Can I Withhold Information?

You may access certain areas of Our Service without providing any personal data at all. However, to use all features and functions available on Our Service You may be required to submit or allow for the collection of certain data.

  1. How Can I Access My Personal Data?

If You want to know what personal data We have about You, You can ask Us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the postal address shown in section 1. Information About Us.

There is not normally any charge for a subject access request. If Your request is ‘manifestly unfounded or excessive’ (for example, if You make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

We will respond to Your subject access request within 30 days of receiving it. Normally, We aim to provide a complete response, including a copy of Your personal data within that time. In some cases, however, particularly if Your request is more complex, more time may be required up to a maximum of three months from the date We receive Your request. You will be kept fully informed of Our progress.

  1. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if We change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Service and You will be deemed to have accepted the terms of the Privacy Policy on Your first use of Our Service following the alterations. We recommend that You check this page regularly to keep up-to-date.

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