INTRODUCTION

Karty LLC is a company duly incorporated under the laws of the Qatar Financial Center, bearing commercial registration number 01234 (“Karty”, “we”, “us” and “our”). Karty is committed to respecting your privacy and safeguarding your personal information. Karty is required to comply with all applicable laws and regulations including Regulation N. 6 of 2005 (“QFC Data Protection Regulations”) and Qatar Financial Centre Authority Data Protection Rules, 2021 (hereinafter collectively referred to as “Law”). We are required to provide you with information about how and why we use personal data. We aim to process information about you fairly, lawfully, and in a transparent manner and the aim of this document is to provide you with sufficient information for you to understand what we are doing with your personal data. 

This Privacy Policy (“Policy”) describes the information collection, use, and sharing practices of Karty with respect to the customer’s (“you”, “your” or “user”) use of the Karty mobile application, website, social media pages, products, tools and any other services that reference this Policy (collectively, the “Services”).

Before you use any of our Services, please review this Policy. By using any part of the Services, regardless of on which platform, you consent to the collection, use, and disclosure of your information as outlined in this Policy. IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY, PLEASE DISCONTINUE USE OF THIS SERVICE. 

All references to “you” or “your,” as applicable, mean the person who accesses, uses, and/or participates in the Services in any manner. If you use the Services on behalf of an entity, you represent and warrant that you have the authority to bind that entity, your acceptance of this Policy will be deemed an acceptance by that entity, and “you” and “your” herein shall refer to that entity.

CONTENTS

1. About Karty

2. Changes to this Policy

3. Information we collect

4. How we use your information

5. Sharing the data

6. Controlling the Data and your rights

7. How long we keep the Data

8. Security

9. Transfers of Personal Data

10. Questions about this Policy
    
    

1. About Karty

Our primary focus is to provide technology services to our customers. In the course of our business operations, we collect, process, and store personal information to deliver and improve our Services. We are committed to protecting your privacy and ensuring that your personal data is handled with transparency, security, and care.

2. Changes to this Policy

We reserve the right to amend this Privacy Policy at any time to reflect changes in the Law, our data collection and use practices, the features of our Services, or advances in technology. If we make a material change to the Privacy Policy, you will be provided with appropriate notice in accordance with the Law. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy. If you do not accept the changes to this Policy, you may close your account by using the account closure option available within your Karty app.

3. Information We Collect

Karty collects information about you and your use of our Services in multiple ways, including when you provide information directly to us through business relationship, any Karty services a user has signed up to and when we passively collect information from you, such as from your browser or device. 

We may also collect personal data from other Third parties or lawfully by accessing publicly available sources or combining different sets of information.

1. Information You Provide Directly To Us

We may collect information from you in a variety of ways, such as:

• Account registration, management, profile creation and modification

• Account access and use, as well as uploading content to the Services and other associated activities;

• Access to and use of the Platforms;

• Submission of payment information;

• Participation in surveys, contests, sweepstakes and promotions sponsored by Karty;

• Signing up to receive alerts via email, text or instant messages from Karty;

• Customer service, technical support, and related communications;

• Participation in communities, commenting on blog entries, interacting with use on social media, and participation in other forums.

• Contact details (e.g., name, address and other contact details such as date and place of birth, nationality and debit cards, prepaid cards and billing details);

• Information about User's given to Karty by filling in forms or by communicating with Karty, whether face-to-face, by phone, e-mail, on-line or otherwise; 

• Information concerning a User’s identity (e.g., passport information or QID which may contain a photograph) or which is relevant for authentication purposes

2. Information Karty collects or generates about the User’s, such as:

• client relationship data (e.g., products held, and services rendered),  payment transaction data and other financial information;

• Information regarding User’s financial situation

• Information Karty collects or generates to comply with its obligations under the anti-money laundering regulatory framework (e.g., information on origin of assets, beneficial ownership);

• Information Karty collects or generates for risk management purposes such as client due diligence data (including periodic review results), client risk profiles, data to assess suitability/appropriateness, client qualification data (e.g., status as business client), screening alerts (transaction screening, name screening), tax data or complaint information;

• Information included in relevant client files and client documentation and other comparable information

• Marketing and sales information (e.g., newsletters, documents received, invitations to and participations at events and special activities, personal preferences and interests, opt-in and opt-out declarations)

• Information used in 'cookies' and similar technologies on websites, mobile applications and in emails to recognize a data subject, remember a data subject’s preferences and show a data subject content Karty thinks he/she/it is interested in

3. Information Karty collects about the User from other sources, such as:

• Communication information (e.g., information contained in emails, chat messages or other digital communications

• Information from publicly available sources and combined information from external sources (e.g., corporate and media broadcasts, information pertaining to social interactions between individuals, organizations, prospects and other stakeholders acquired from companies that collect combined information).

Karty may also collect and process additional Personal Data about which Karty will inform you from time to time.

4. How We Use Your Information

We may use the information we collect from and about you for the following purposes:

• Providing and managing our products and services to you

• To improve and develop our business

• Responding to any queries, requests or complaints 

• Complying with legal and regulatory obligations including verifying your identity 

• To manage outrights, terms of use or any other contractual obligations we have with you

• To prevent, detect and prosecute fraud and other crimes

• Conducting research and data analytics

• Marketing and promotional activities

• Communicate to you through all Karty channels including email and SMS

• Processing transactions and financial payments

• Monitoring and recording communications

Without prejudice to any of the provisions of the Law, we process your personal data, under the following legal basis:

1. Your consent; 

2. the processing is necessary:

3. to perform a contract to which the User is a party; or 

4. in order to take steps at the User’s request before entering into a contract.

5. the Processing is necessary to comply with an obligation imposed on Karty by Law; 

6. the processing is necessary to protect the vital interests of the User or another individual

7. the Processing is necessary to perform a task carried out:

   (1)in the public interest; or

   (2) by any of the following in the performance of its functions: 

   • the QFC Authority;

   • the QFC Regulatory Authority; 

   • the Civil and Commercial Court;

   • the Regulatory Tribunal; or 

   • a QFC Institution

h. the Processing is necessary for the purposes of the legitimate interests of Karty or another Person to whom the data are disclosed (unless those interests are overridden by the rights and legitimate interests of the User that require the data to be protected).

5. Sharing the Data

Karty may share your personal data with other organisations to enable us to provide our services to you where we:

• Are under a legal duty to comply with any legal obligation under Law or in order to enforce or apply our terms and conditions; 

• Need to disclose it to protect our rights, property or safety of our users or others, including the exchange of information with other companies, organisation and/or governmental bodies for the purposes of fraud protection and credit risk reduction;

• Police, Law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security;

• Other organisations as we may determine from time to time such as payment processors; and

• Third parties who assist us in operating our business.

  
  

6. Controlling Your Data and Your Rights

1.  Controlling your Data

We are obliged to provide clear and transparent information about our processing activities of your personal data, this is done through our Privacy Policy.

2. Your Rights

You have certain rights relating to the personal information we hold about you which are outlined below, they may be subject to various exceptions and limitations. You can exercise these rights at any time by contacting support@karty.qa 

Under applicable data protection law, you may have rights including access to and erasure of your personal data, the ability to request rectification of inaccurate data, and the right to restrict processing under certain conditions. Additionally, you can object to processing based on your specific situation and request data portability. You also have the right not to be subjected to decisions based solely on automated processing that could significantly affect you. If your personal data is obtained from a third party, you will be informed within a reasonable period, no longer than 30 days, as required by law. Furthermore, you have the right to lodge complaints with the Data Protection Office and seek compensation if you suffer any harm due to non-compliance with data protection laws.

If Karty processes your personal data based on your consent, you have the right to revoke that consent at any time. Upon revocation, we will stop processing your data unless legally required to do so. Please note that the revocation will not affect the processing that took place before it was withdrawn, and we may still process your data if we have another legitimate reason.

7. How Long we Keep Your Data

We will keep your data to enable us to continue to provide you with products and services and to assist us in managing our relationship with you including; verifying your identity when you contact us or when you apply for products or services, preventing fraud and assessing your suitability for products or services you have applied for. We will keep this information for as long as you keep your services with us and using our platforms (e.g. Mobile App). We may keep this information after you stop using our platforms, for instance, to respond to enquiries and complaints, as required by Law and regulations or to protect our interests. If the data is no longer required in order to fulfill contractual or statutory obligations, it is deleted, unless its further processing is required – for a limited time.

The provisions under Article (19) of the QFC Data Protection Regulation shall be applicable if you object to Karty’s retention of data.

8. Security

We take technical, physical and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is secure. 

We have appropriate security measures in place on our Websites, Mobile App and electronic devices to prevent personal information from being accidentally lost, used or accessed in an unauthorized way. Access will be limited to those who have a genuine business interest and/ or a need to know, and will only process your information in an authorized manner and they will be subject to a duty of confidentiality. We also have procedures to deal with any suspected data security breach.  We will notify you and any applicable regulator of a suspected data security breach, as required by law. 

We encourage you to take steps to protect your information and prevent unauthorized access to your password or account by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.

If you believe that any of your account login or authentication credentials have been compromised, stolen or been made known to others, you must contact us immediately at support@karty.qa  change your details and make reasonable efforts to secure your account immediately. 

9. Transfers of Personal Data

Karty shall ensure that any transfer of Personal Data within or outside the QFC shall be carried out in accordance with the provisions of Articles 23 and 24 of the QFC Data Protection Regulation.

10. Questions About this Policy

You may exercise your rights or make a request regarding your information held by us, request further information about your legal rights under applicable law, or submit a complaint about our privacy practices by contacting us at any time, using the contact details set forth in this section below.

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances. If we need to keep processing your information to provide services to you or to comply with a legal obligation. Moreover, you will not be permitted to examine the information of any other person or entity. We also may request you provide us with information necessary to confirm your identity before responding to your request.

If you have any questions about this Privacy Policy, would like to exercise your rights regarding your information that we hold, or would like to raise a complaint with us related to your information, you should contact us by emailing support@karty.qa