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DOORLY PRIVACY POLICY

Last edited at: 23rd September 2025

1. INTRODUCTION

  1. Doorly Technologies LTD (the “Company”, “we”, “us” or “our”), a company duly incorporated and registered in the Abu Dhabi Global Market (the “ADGM”) as a limited liability company, whose registration number is 31028, and whose registered address is at Office 3801, Addax Port Office Tower, Al Reem Island, ADGM, Abu Dhabi, UAE. Our products and services include “Doorly Application” (“Doorly”), an application interface designed to provide you and others (“you”, “your”, the “User”, and collectively the “Users”) with a platform to upload and share content, and interact with other Users, (together with any services provided by us in connection with Doorly, the “Services”.
  2. Definitions and interpretations used in this policy (the “Policy”), shall have the same meaning ascribed thereto into the terms and conditions for Doorly, unless otherwise expressly defined or demanded by context.
  3. We are committed to safeguarding the privacy of the personal information that is provided to us or collected by us during the course of our business, as well as the personal information we receive from you, for the purpose of providing the Services. This Policy describes how and why we collect, store and use personal information, and provides information about your rights in relation thereto.
  4. Please read thoroughly this Policy and ensure your understanding of the terms thereof. The Company reserves the right to amend or update this Policy from time to time at its sole discretion; kindly refer to the section on “Changes to this Privacy Policy” hereunder for more details. You can view the most recent version of this Policy by accessing this online address.
  5. For the purposes of applicable data protection law, the Company is the “data controller” of your personal information.
  6. By using any of the Services or otherwise interacting in your capacity as a User with Doorly, you hereby provide your consent for your personal data and any other data, including financial credentials, referenced under this Policy to be collected by the Company and used in accordance with the terms set forth hereunder. If you do not consent to the terms of this Policy, or any amendments added thereto at any later date, please exit Doorly and refrain from using any of the Services provided through it.
 
2. COLLECTION OF PERSONAL INFORMATION
  1. By using any of the Services, you consent to our collection, use and disclosure of your personal information in accordance with the terms of this Policy. You may withdraw such consent at any time. However, this will not affect the lawfulness of the collection or processing of any data based on your consent prior to the withdrawal, or where we have other legitimate or otherwise legally required purposes for processing your personal data.
  2. We may collect and process the following personal information:
    1. Information you give us:
      1. If you are enquiring through the Services, then we may request and process with your consent your personal information including but not limited to, your name, e-mail address, telephone number, ID, passport, address and date of birth.
      2. We may also request permission to process your sensitive personal information, including but not limited to, your: genetic data and biometric data used to identify you, signature and any data collected and processed from the contracts you enter into this could include health, financial or other sensitive personal data.
      3. You may give us information about you when using the Services or by corresponding with us by phone, e-mail or other electronic means, or in writing, as well as other information you provide directly to us, including in conversation with our employees and staff.
    2. Information we collect about you:
      1. With regard to your use of the Services, we may automatically collect the following information:
        1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system; location (home and / or office); and
        2. information about your use of the Services, Services you viewed or searched for, page response times, download errors, length of visits, page interaction information (such as scrolling, clicks, and mouse-overs). 
    3. We may also receive information about you from other sources such as our local authorised business partners and service providers.

 

3. PURPOSE
  1. We use your personal information for the following purposes, to the extent permitted by applicable law:
    1. Where this is necessary for purposes which are in our, or third parties’, legitimate interests. These interests include:
      1. auditing usage of the Services;
      2. processing and responding to User enquiries;
      3. providing our Services; and
      4. otherwise implementing transactions or communications as requested by you, other Users, and/or third parties with whom the Company deals with to provide the Services, and generally providing you with the services and information you requested through use of the Services.
    2. To improve the commercial practices of the Company and the efficiency and user experience of Doorly.
    3. To protect the security and integrity of the personal data collected and processed by the Company in compliance with this Policy.
    4. For administrative purposes.
    5. To inform you of any material changes or alterations that occur to this Policy.
    6. Where you give us consent, to send you newsletters related to our Services and for other marketing purposes.
    7. For purposes which are required by law, including:
      1. responding to requests by government or law enforcement authorities conducting an investigation;
      2. complying with any applicable legislation; and
      3.  responding to requests by a competent court or enforcing a judgement.

 

4. SHARING YOUR PERSONAL INFORMATION
  1. We may disclose your personal information to affiliates and subsidiaries of the Company.
  2. We may also share your personal information with third parties, including certain service providers we have retained in connection with our business activities or other entities as found necessary.
  3. Moreover, we may disclose your personal information to third parties: 
    1. if we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
    2. if the Company, its business, or its assets are acquired by a third party, in which case personal information held by it about its Users will be one of the transferred assets;
    3. if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or if we are required to do so by a legal process, or in order to enforce or apply our terms and conditions and other agreements; or if we reasonably consider this necessary; or to protect the rights, property, or safety of the Company or our Users, or others; and
    4. for the purposes of crime prevention and fraud protection.
  4. We may also disclose your personal information to law enforcement authorities or other government officials.
  5. We may also disclose your personal information to any competent administrative or judicial authority in prevention of money laundering and terrorist financing in compliance with any anti-money laundering regulation for the purposes of preventing any operation related to money laundering or terrorism financing.
  6. We will use all reasonable efforts to ensure the safeguarding, security and confidentiality of all collected personal information subject to data transfers by implementing appropriate technical and organisational measures to ensure a level of security to the risk, and to have in place generally accepted information security mechanisms to prevent unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data the Company collects. These measures include, to the extent allowed by law, policies, procedures, firewalls, access control procedures, encryption, and technical elements relating to personal data access controls.

 

5. COOKIES AND INTERNET ADVERTISING
  1. We use ‘cookies’ to improve our user’s experience. Cookies are small files that are sent to a computer's hard drive by a webserver and enable websites and mobile applications to remember who you are. Information from cookies may include information relating to your use of Doorly, information about your computer (such as IP address and browser type), and demographic data.  The list below sets out the types of cookies we use, and the purposes for which we use them.

    Type of cookie

    Why we use these cookies 

    Authentication 

    This cookie is essential for a single user to login (using a username and password) and access restricted areas of Doorly.

    Necessary 

    We use these cookies to run Doorly, and to identify and prevent security risks. For example, we may use these cookies to store your session information to prevent others from changing your password without your username and password. These cookies are by definition necessary for the operation of Doorly and cannot be switched off for purposes of accessing Doorly or using the Services.

    Preferences 

    We use these cookies to remember your settings and preferences, and to improve your experience on Doorly. For example, we may use these cookies to remember your language preferences. 

    Performance 

    We use these cookies to collect information about how you use Doorly, monitor its performance, and improve its performance, our Services, and your experience. For example, we can use these cookies to learn more about which features are the most popular with our users and which ones might need some tweaks. All information collected via these cookies is anonymous.

    Marketing 

    We use these cookies to deliver adverts, to make them more relevant and meaningful to you, and to track the efficiency of our advertising campaigns, both on our services and on other sites or mobile applications. 
  2. We also use advertising identifiers which are similar to cookies and are found on many mobile devices and tablets. Like cookies, advertising identifiers are used to make online advertising more relevant.  Advertising cookies and advertising identifiers use information about your use of this and other websites and applications, your response to ads and emails, and to deliver ads that are more relevant to you. These types of ads are called “internet-based advertising”.

 

6. USE OF LINKS
  1. Doorly may contain links to other third-party websites. The Company has no control over the content, policies or actions of these websites. Notwithstanding any legislative provisions in any of the territories wherein the Company provides Services, the use of any information you may provide to third parties on other websites, or which such parties may otherwise collect on other websites, is not governed by this Policy. You should carefully review the privacy policies and protection of personal data measures of any third-party websites and contact the operators of those websites if you have any questions about their use of your information. The Company shall not be responsible for any third party, its affiliates or agents, for failing to use your personal information in accordance with such third party’s privacy policy and/or practices, or any contractual or other legal obligations to which such third party, its affiliates or agents, may be subject to.

 

7. SECURITY
  1. We use up-to-date information storage and security to hold your personal information securely in electronic and physical form to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. Whilst we have implemented adequate physical, electronic and managerial procedures to secure and safeguard your personal information, guaranteed security does not exist either on or off the internet; we shall practice commercially reasonable efforts to make the collection and security of your personal data compliant with this Policy and all applicable laws, regulations and best practice standards. 
  2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where and to the extent we are legally required to do so.
  3. We will regularly evaluate and test the effectiveness of the safeguards referenced under this clause 7 to ensure security of our processing of your personal data access by third parties, and we cannot guarantee in this respect that the personal information provided by you or that is transmitted via the Services or by e-mail is totally secure and safe, and you provide it at your own risk. 

 

8. CROSS-BORDER TRANSFERS
  1. Your personal information may be transferred to and stored in servers and facilities located in your region or another country.  Some of these countries do not provide the same level of data protection as the country in which you reside and are not recognised by the European Commission as providing an adequate level of protection.  
  2. When we transfer your information to other countries, we will use, share and safeguard that information as described in this Policy. To conduct the services, we may transfer the personal information we collect to countries which do not provide the same level of data protection as the country in which you reside and are not recognised by the European Commission as providing an adequate level of data protection. We only transfer personal information to these countries, with your consent, when it is necessary to provide the Services, or subject to appropriate safeguards that assure the protection of your personal information, such as standard contractual clauses. 

 

9. MARKETING COMMUNICATIONS
  1. We, or trusted third parties on our behalf, may contact you by email or post with information about our services or promotions that might be of interest to you. Where necessary, at the time that you provide your personal information to us, you will be given the opportunity to indicate whether or not you are happy for us to use your personal information in order to tell you about such services and promotions.
  2. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services. You may, at any time, withdraw your consent to receive commercial marketing communications by email at [email protected].

 

10. YOUR RIGHTS
  1. You have the right to ask us to provide a copy of the personal information we hold about you, and to have personal information removed or any inaccurate personal information about you corrected.
  2. If you would like your personal information to be removed from our records or if your personal information requires amending then we will endeavor to correct, update or remove your personal information as swiftly as possible. You can make such request by [email protected].

 

11. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
  1. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.   
  2. Your personal information that is processed for marketing purposes will be stored until you exercise the right to withdraw consent, and once such right is exercised, your personal information will be kept only during the applicable statute of limitations period for any disputes or liabilities that may arise as a consequence of the processing of that information. Once potential actions are time-barred we will proceed to delete the personal data. In any other circumstances, we will only retain your personal information for a shorter or longer period as required by any applicable law.

 

12. CHANGES TO THIS PRIVACY POLICY

  1. By using Doorly, you consent to the collection, use and disclosure of your personal information as described in this Policy. This Policy reflects the Company’s current business practices and is subject to changes, alterations and updates. In the event of any changes, alterations or updates, this Policy will be updated accordingly, with the last date of update noted on the bottom of the page. Please check this Policy periodically to remain informed of any changes or updates to the Company’s privacy policies and practices. If you allow the Company to retain your personal information you provide to us via Doorly in its customer database, and the Company intends to disclose that information to third parties or affiliates in a manner that is not already outlined in this Policy, the Company will notify you as soon as possible by e-mail and provide you with an opportunity to refuse any further use or disclosure of your personal information. 

 

13. CONTACT US

  1. If you have any questions about this Policy, or our processing of your personal data, please contact us via [email protected].