1. Introduction
Tathmeer.ai (“Tathmeer”, “we”, “us”, or “our”) is committed to protecting the privacy, confidentiality, and security of the personal data and information entrusted to us by users of our services. This Privacy & Data Protection Policy (“Privacy Policy”) explains how Tathmeer collects, receives, accesses, uses, processes, stores, retains, discloses, transfers, and protects personal data in connection with the Tathmeer.ai website, mobile applications, digital platforms, artificial intelligence capabilities, agricultural services, marketplace services, technology and innovation services, incubation activities, communications, and any other products or services made available by Tathmeer from time to time (collectively, the “Services”).
This Privacy Policy applies to all individuals and entities who access or use the Services, including farmers, buyers, sellers, technology providers, technology partners, innovators, agricultural experts, professionals, investors, visitors, and other participants in the Tathmeer ecosystem, to the extent that Tathmeer processes personal data relating to them.
This Privacy Policy also applies to personal data collected through the Tathmeer website, mobile applications, online registration and onboarding processes, questionnaires, forms, artificial intelligence interactions, marketplace activities, agricultural and farm-management activities, technology testing and demonstration activities, innovation and incubation activities, customer support interactions, communications, cookies, software development kits (“SDKs”), analytics technologies, logs, and other digital or physical interactions through which personal data may be collected or processed by or on behalf of Tathmeer.
By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. Where applicable law requires Tathmeer to obtain your consent for a particular processing activity, Tathmeer will seek and record such consent in accordance with the applicable legal requirements. Your continued use of the Services following an update to this Privacy Policy may constitute acknowledgment of the updated policy to the extent permitted by applicable law.
2. Applicable Data Protection Framework
Tathmeer processes personal data in accordance with applicable laws and regulations of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data, as applicable to the relevant processing activity.
Tathmeer may also be subject to other applicable UAE laws and regulatory requirements relating to electronic transactions, cybersecurity, consumer protection, digital services, communications, contractual relationships, commercial activities, and other matters depending upon the nature of the Services and the circumstances in which personal data is processed.
Where mandatory legal requirements impose a higher standard of protection than the practices described in this Privacy Policy, Tathmeer will seek to comply with such requirements to the extent applicable to the relevant processing activity.
Nothing in this Privacy Policy is intended to limit or exclude any rights or protections that cannot lawfully be limited or excluded under applicable law.
3. Responsibility for Personal Data
Tathmeer is responsible for determining the purposes and means of processing personal data undertaken in connection with the Services, subject to the applicable legal and contractual framework.
Tathmeer may engage third-party service providers, technology providers, hosting providers, analytics providers, communication providers, payment service providers, artificial intelligence service providers, security providers, professional advisers, and other contractors to process personal data on behalf of Tathmeer. Where such third parties process personal data on behalf of Tathmeer, Tathmeer will seek to implement appropriate contractual, technical, and organizational measures governing such processing, consistent with applicable law.
For privacy-related enquiries, requests, complaints, or concerns, users may contact the Tathmeer Compliance Manager at support@tathmeer.ai.
4. Meaning of Personal Data
For purposes of this Privacy Policy, “Personal Data” means information relating to an identified or identifiable natural person, or information that can reasonably be used to identify an individual directly or indirectly.
Personal Data may include information provided directly by you, information generated through your use of the Services, information collected automatically from your device, information obtained from third parties where legally permitted, and information generated through interactions between you and the Tathmeer platform.
Information that has been permanently anonymized in such a manner that the individual can no longer reasonably be identified may cease to constitute Personal Data under applicable law. Tathmeer may use such anonymized information for legitimate business, analytical, research, development, operational, and statistical purposes.
5. Information Tathmeer May Collect
Tathmeer may collect and process different categories of information depending on the Services you use, your role within the Tathmeer ecosystem, the information you voluntarily provide, and the manner in which you interact with the platform.
When you create an account or otherwise register for the Services, Tathmeer may collect information necessary to establish and manage your account, verify your identity where appropriate, communicate with you, provide requested Services, maintain platform security, and comply with applicable legal requirements. Such information may include your name, email address, telephone number, account credentials, profile information, role, professional information, business information, and other registration information.
Where you create a user profile, Tathmeer may collect information relating to your selected role and your participation in the ecosystem. Depending on the relevant role, this may include information concerning agricultural activities, professional experience, business activities, products and services, technical capabilities, areas of expertise, innovation ideas, projects, investment interests, marketplace participation, or other information relevant to providing the Services.
Where you use agricultural, farm-management, advisory, monitoring, or related Services, Tathmeer may collect information concerning farms and agricultural operations. Such information may include farm characteristics, crop information, cultivation practices, irrigation information, soil information, agricultural activities, crop-health information, pest and disease observations, production information, farm-management information, photographs, videos, documents, sensor information, technology-generated data, and other information submitted or generated through the relevant Services.
Where farm or agricultural information is associated with an identifiable individual, such information may constitute Personal Data and will be processed in accordance with this Privacy Policy and applicable law.
Tathmeer may collect information relating to marketplace activities, including information concerning products or services listed or requested, transactions, orders, communications, delivery-related information, payment-related information where processed through or on behalf of Tathmeer, disputes, reviews, and other information necessary to facilitate marketplace interactions.
Technology providers and technology partners may be required to provide information concerning their organization, products, technologies, capabilities, certifications, demonstrations, technical documentation, projects, services, commercial information, and other information necessary to assess, present, test, validate, or facilitate their participation in the Tathmeer ecosystem.
Innovators participating in Tathmeer innovation or incubation activities may provide information relating to their ideas, projects, proposed agricultural solutions, business models, technical concepts, development activities, supporting documentation, team information, and other information required to evaluate or support their innovation journey.
Tathmeer may also collect information relating to communications between you and Tathmeer, including enquiries, support requests, feedback, correspondence, submissions, and records of communications where necessary for service delivery, quality assurance, dispute resolution, security, compliance, or legitimate business purposes.
6. Information Collected Through the Website
When you access the Tathmeer website, certain information may be collected automatically by Tathmeer or by technologies used on our behalf. This may include your Internet Protocol address, browser type, operating system, device characteristics, referring website, pages visited, date and time of access, approximate geographic information, interaction information, error information, and technical logs.
Tathmeer may use this information to operate the website, maintain security, identify and resolve technical issues, understand usage patterns, improve functionality, monitor performance, prevent abuse, detect unauthorized activity, and maintain appropriate records.
Where information collected through the website constitutes Personal Data, Tathmeer will process such information in accordance with this Privacy Policy and applicable law.
7. Information Collected Through the Mobile Application
When you use a Tathmeer mobile application, the application may collect information necessary to provide the requested functionality and maintain the security and performance of the application.
Depending on the features you use and the permissions granted on your device, the application may access information such as device identifiers, operating system information, application version, network information, usage information, crash information, notification tokens, location information, photographs, videos, files, camera functionality, microphone functionality, or other device permissions.
Tathmeer will request device permissions where required for particular features. You may be able to modify certain permissions through your device settings; however, restricting a permission may prevent or limit the availability of the functionality for which that permission is required.
8. Information Voluntarily Provided by Users
You may voluntarily provide Personal Data when creating an account, completing onboarding questions, creating or updating a profile, submitting farm information, uploading documents or photographs, communicating with Tathmeer, using AI features, participating in marketplace activities, submitting an innovation idea, interacting with technology providers, requesting support, submitting feedback, or using other features of the Services.
You are responsible for ensuring that information voluntarily provided to Tathmeer is accurate, complete, current, and not misleading. Where you provide information relating to another individual, you represent that you are authorized to provide such information and that its provision and use through the Services does not unlawfully infringe the rights of that individual.
9. Purposes for Processing Personal Data
Tathmeer may process Personal Data for the purposes necessary to provide, operate, administer, maintain, secure, improve, and develop the Services.
This may include processing Personal Data to create and manage user accounts; authenticate users; establish user profiles; determine relevant platform functionality; provide agricultural information and recommendations; operate AI-powered features; facilitate communication between users and ecosystem participants; support marketplace activities; connect farmers with buyers, sellers, technology providers, experts, innovators, investors, or other participants; support technology demonstrations and validation; administer innovation and incubation activities; provide customer and technical support; process or facilitate transactions where applicable; manage communications; maintain platform security; detect fraud, misuse, unauthorized access, and other prohibited activity; investigate complaints and disputes; comply with legal and regulatory obligations; enforce contractual terms; maintain business and operational records; conduct analytics; improve products and services; and protect the rights, property, safety, and legitimate interests of Tathmeer, its users, and other parties.
Tathmeer may also process information for research, statistical, analytical, product-development, service-improvement, and business-planning purposes, provided that such processing is conducted in accordance with applicable law and appropriate safeguards.
10. Legal Basis for Processing
Tathmeer will process Personal Data on an appropriate legal basis under applicable law. Depending on the nature and circumstances of the processing, the legal basis may include your consent, the necessity of processing to perform a contract or provide a requested service, compliance with a legal obligation, protection of legitimate interests, or another lawful basis recognized under applicable law.
Where consent is required, Tathmeer will seek consent through an appropriate mechanism and will maintain appropriate records of such consent. Where applicable law provides a right to withdraw consent, users may exercise that right by contacting Tathmeer at support@tathmeer.ai, although withdrawal of consent may affect Tathmeer’s ability to provide certain Services where the relevant processing is necessary for those Services.
Withdrawal of consent will not affect the lawfulness of processing that occurred before consent was withdrawn.
11. Data Minimization and Privacy by Design
Tathmeer seeks to collect and process Personal Data that is reasonably necessary for the purposes for which it is collected. Tathmeer does not intend to collect Personal Data merely because it is technically available where such information is not reasonably required for the relevant purpose.
Tathmeer seeks to incorporate privacy and data protection considerations into the design, development, implementation, modification, and operation of its Services. The nature and extent of these measures may vary depending on the sensitivity and volume of data processed, the purpose of processing, technological considerations, applicable legal requirements, and the associated risks.
12. Agricultural and Farm Data
Agricultural and farm information may be central to the Services provided by Tathmeer. Such information may be used to generate insights, recommendations, reports, monitoring information, analytics, project-management information, agricultural assessments, or other outputs requested by the user.
Users acknowledge that information concerning farms, crops, agricultural operations, environmental conditions, and related activities may be processed by automated systems, artificial intelligence systems, technology providers, experts, or other authorized service providers where necessary to deliver the relevant Services.
Tathmeer will seek to apply appropriate access controls to agricultural information. However, users should understand that information voluntarily shared with other users, technology providers, experts, buyers, sellers, or other ecosystem participants may be subject to the terms applicable to those interactions.
Users should not submit confidential or commercially sensitive information through a feature unless they understand the intended audience and manner in which that information may be processed or shared.
13. Artificial Intelligence and Automated Processing
Tathmeer may use artificial intelligence, machine learning, automated processing, algorithms, analytical systems, and related technologies as part of its Services.
AI systems may process information submitted by users, including questions, agricultural information, farm information, images, documents, project information, marketplace information, and other content provided through the Services, in order to generate responses, recommendations, analyses, classifications, summaries, alerts, insights, or other outputs.
AI-generated outputs are provided for informational and decision-support purposes unless expressly stated otherwise. Users remain responsible for evaluating the suitability, accuracy, completeness, and relevance of AI-generated outputs before relying upon them, particularly where decisions may materially affect agricultural operations, financial matters, business activities, safety, regulatory compliance, or other significant matters.
Tathmeer may use third-party artificial intelligence or technology providers to support certain AI capabilities. Where Personal Data is processed by such providers, Tathmeer will seek to implement appropriate contractual and technical safeguards consistent with applicable law and the intended purpose of the processing.
Tathmeer may also process AI interaction data for purposes such as service delivery, security, quality assurance, troubleshooting, system improvement, analytics, and development, subject to applicable law and the configuration of the relevant Service.
15. Analytics and Service Improvement
Tathmeer may use analytics and performance information to understand how users interact with the Services, identify areas for improvement, measure functionality, monitor performance, troubleshoot technical problems, improve user experience, and develop new products and features.
Where analytics information is Personal Data, it will be processed in accordance with this Privacy Policy and applicable law.
Tathmeer may use aggregated, statistical, or anonymized information for research, analytics, reporting, benchmarking, business planning, product development, and other legitimate purposes where such information cannot reasonably be used to identify an individual.
16. Mobile Notifications
Where you enable notifications, Tathmeer may use your device or application notification identifier to deliver service-related notifications, alerts, reminders, updates, security messages, agricultural information, marketplace notifications, or other communications relevant to your use of the Services.
You may be able to disable notifications through your device settings or application settings. Certain essential service or security communications may continue where necessary and legally permitted.
17. Location Information
Certain Tathmeer features may require or benefit from access to location information. Location information may be used for purposes such as identifying the relevant geographic context of a farm, supporting agricultural recommendations, providing location-relevant Services, improving monitoring capabilities, enabling location-based functionality, enhancing security, or connecting users with relevant ecosystem participants.
Where a feature requires location access, Tathmeer may request the relevant permission through the website, mobile application, or device operating system.
Users should understand that the accuracy of location information may vary depending on the device, network, satellite availability, permissions, and other technical factors.
18. Camera, Microphone, Photographs, Videos and Files
Certain Tathmeer features may allow users to upload photographs, videos, documents, files, or other content, including photographs of crops, plants, farms, equipment, agricultural conditions, products, or other materials.
Where applicable, the mobile application may request access to the device camera, microphone, photo library, media library, or file storage. Such access will be used for the functionality initiated or enabled by the user and subject to the relevant device permissions.
Users should not upload photographs, videos, documents, recordings, or other content containing Personal Data relating to other individuals unless they have the appropriate authority or lawful basis to do so.
19. Sharing of Personal Data
Tathmeer may share Personal Data where such sharing is reasonably necessary for the provision, operation, administration, security, improvement, or development of the Services, or where otherwise permitted or required by applicable law.
Depending on the Services used and the user’s interactions, Personal Data may be shared with other users or ecosystem participants where the user has chosen to interact with them or where such sharing is necessary to provide a requested service.
For example, information may be shared between a farmer and a relevant technology provider, expert, buyer, seller, innovator, investor, or other participant where such sharing is necessary to facilitate an interaction requested or initiated through the platform.
Tathmeer may also share Personal Data with service providers that provide hosting, cloud infrastructure, authentication, communication, analytics, cybersecurity, payment processing, customer support, software development, artificial intelligence, monitoring, maintenance, or other services to Tathmeer.
Tathmeer may disclose Personal Data to professional advisers, auditors, insurers, legal advisers, accountants, consultants, or other professional service providers where reasonably necessary for legitimate business, legal, compliance, audit, risk-management, or dispute-resolution purposes.
Tathmeer may disclose Personal Data to government authorities, regulators, courts, law-enforcement bodies, or other authorized entities where required or permitted by applicable law or where reasonably necessary to protect the rights, safety, security, or property of Tathmeer, users, or other persons.
Tathmeer may also disclose information in connection with a merger, acquisition, restructuring, financing, sale of assets, corporate reorganization, or similar business transaction, subject to applicable legal requirements and appropriate confidentiality and data-protection measures.
20. Third-Party Service Providers
Tathmeer may rely on third-party providers to support its Services. Such providers may process Personal Data on behalf of Tathmeer or may process information independently where permitted by applicable law.
Tathmeer seeks to select service providers that provide appropriate technical and organizational safeguards and, where appropriate, enters into agreements addressing confidentiality, security, permitted processing, data protection, access, retention, and deletion requirements.
Third-party service providers may include providers of cloud hosting, databases, authentication, messaging, email, analytics, cybersecurity, payment services, artificial intelligence, software infrastructure, customer support, monitoring, application services, and other technology services.
The availability and identity of third-party providers may change as Tathmeer develops its technology and Services.
21. International and Cross-Border Transfers
Personal Data may be stored, accessed, processed, or transferred across borders where necessary for the provision of the Services, use of third-party service providers, technical infrastructure, business operations, or other legitimate processing purposes.
Where Personal Data is transferred outside the United Arab Emirates or otherwise subject to cross-border transfer requirements, Tathmeer will seek to comply with applicable legal requirements governing such transfers and implement appropriate safeguards where required.
Users acknowledge that cloud infrastructure and third-party technology providers may operate systems in multiple jurisdictions. Tathmeer will seek to ensure that such arrangements are subject to appropriate contractual, technical, and organizational safeguards.
22. Data Security
Tathmeer takes reasonable technical and organizational measures designed to protect Personal Data against unauthorized access, alteration, disclosure, loss, destruction, misuse, or other unlawful or unauthorized processing.
Security measures may include access controls, authentication mechanisms, encryption where appropriate, network and infrastructure security, logging and monitoring, secure software-development practices, backup and recovery mechanisms, vulnerability management, personnel controls, and incident-management procedures.
No electronic transmission, storage system, or internet-based service can be guaranteed to be completely secure. Accordingly, while Tathmeer seeks to protect Personal Data using appropriate safeguards, Tathmeer cannot guarantee that unauthorized access, security incidents, or other events will never occur.
23. Data Breaches and Security Incidents
Where Tathmeer becomes aware of a Personal Data breach or security incident affecting Personal Data, Tathmeer will assess and respond to the incident in accordance with applicable law and its internal incident-response procedures.
Depending on the nature and severity of the incident and applicable legal requirements, Tathmeer may investigate the incident, contain and remediate the issue, assess affected data, implement corrective measures, notify relevant authorities, and notify affected individuals where legally required or otherwise appropriate.
24. Data Retention
Tathmeer will retain Personal Data for no longer than reasonably necessary for the purpose for which it was collected or processed, unless a longer retention period is required or permitted by applicable law, contractual obligations, dispute-resolution requirements, security requirements, legitimate business requirements, or other lawful purposes.
Retention periods may vary depending on the category and nature of the data, the purpose of processing, the user’s relationship with Tathmeer, legal and regulatory requirements, security considerations, and the need to establish, exercise, or defend legal claims.
When Personal Data is no longer required, Tathmeer will seek to delete, anonymize, or otherwise securely dispose of it in accordance with applicable law and Tathmeer’s retention and deletion procedures.
25. Data Subject Rights
Subject to applicable law and any applicable limitations or exemptions, individuals may have rights relating to their Personal Data.
Such rights may include the right to request access to Personal Data held by Tathmeer, request correction or updating of inaccurate or incomplete Personal Data, request restriction or cessation of certain processing, withdraw consent where processing is based on consent, object to certain processing where applicable, and exercise other rights provided under applicable law.
The availability and scope of these rights may depend on the nature of the processing activity, the applicable legal basis, applicable exemptions, and other requirements under UAE law.
26. Exercising Privacy Rights
Users wishing to exercise a privacy or data-protection right may contact the Tathmeer Compliance Manager at support@tathmeer.ai.
Tathmeer may request sufficient information to verify the identity of the requesting individual before processing a request. This verification requirement is intended to protect Personal Data from unauthorized disclosure.
Tathmeer will assess requests in accordance with applicable law and will respond within the applicable legal timeframe.
Where Tathmeer is unable to fully comply with a request, Tathmeer may explain the applicable legal, contractual, security, or operational reason to the extent permitted by law.
27. Marketing Communications
Where permitted by applicable law, Tathmeer may send users communications concerning Services, platform updates, agricultural information, educational content, ecosystem opportunities, events, products, services, or other information that may be relevant to their relationship with Tathmeer.
Where applicable law requires consent for direct marketing communications, Tathmeer will seek the required consent.
Users may request to stop receiving promotional communications by using the available unsubscribe mechanism or by contacting Tathmeer at support@tathmeer.ai.
Tathmeer may continue to send essential service, security, transactional, account, legal, or administrative communications where necessary.
28. Information Relating to Other Individuals
Users must not provide Personal Data belonging to another individual unless they have the authority, permission, or other lawful basis required to provide that information to Tathmeer and for Tathmeer to process it for the relevant purpose.
Where users upload photographs, documents, videos, recordings, contact information, or other materials containing information relating to other individuals, the user is responsible for ensuring that such submission does not unlawfully infringe the privacy or other rights of those individuals.
29. Children and Minors
The Services are not intended to knowingly collect Personal Data from children in circumstances where such collection is prohibited by applicable law.
Where applicable law requires parental or guardian consent for the collection or processing of a minor’s Personal Data, Tathmeer will seek to implement appropriate measures consistent with those requirements.
If Tathmeer becomes aware that Personal Data has been collected from a child in circumstances where such collection was not permitted, Tathmeer may take reasonable steps to delete or otherwise appropriately address such information.
30. Public Profiles and User-Generated Content
Certain features of the Tathmeer platform may allow users to create profiles, publish information, submit listings, upload content, participate in discussions, provide reviews, communicate with other users, or otherwise make information available to other participants.
Users should carefully consider the information they choose to publish or share through such features.
Information intentionally made available to other users or publicly through the Services may no longer be treated as confidential and may be accessible to persons beyond the original recipient.
Tathmeer is not responsible for the independent collection, use, disclosure, or retention of information by another user where such processing occurs outside Tathmeer’s control and is not undertaken on behalf of Tathmeer.
31. Data Sharing Between Platform Participants
The Tathmeer ecosystem is designed to facilitate interactions between different participants, including farmers, buyers, sellers, technology providers, experts, innovators, investors, and other ecosystem participants.
Where a user chooses to engage with another participant through the Services, certain information may be made available to that participant to facilitate the relevant interaction.
Users acknowledge that Tathmeer may not control how an independent participant subsequently uses information that the participant lawfully receives directly from another user. Users should therefore exercise appropriate discretion when sharing Personal Data, confidential information, business information, farm information, intellectual property, or commercially sensitive information.
32. Confidential and Commercially Sensitive Information
Users may provide information that they consider commercially sensitive, proprietary, confidential, or otherwise valuable.
Unless expressly agreed otherwise, users should not assume that information submitted through a platform feature is confidential merely because it is submitted to Tathmeer.
Where a feature involves sharing information with another user, technology provider, expert, investor, buyer, seller, innovator, or other ecosystem participant, the user is responsible for reviewing the applicable terms and understanding the intended disclosure.
Tathmeer will seek to protect information within its control through appropriate security and access controls; however, Tathmeer cannot guarantee the confidentiality of information that a user intentionally makes available to another independent participant.
33. Ownership of Personal Data and User Content
Users retain rights in their Personal Data and content to the extent provided by applicable law.
Nothing in this Privacy Policy transfers ownership of a user’s Personal Data or proprietary content to Tathmeer.
However, users grant Tathmeer the rights necessary to collect, process, store, transmit, analyze, display, and otherwise use information to the extent reasonably required to provide and operate the Services and for other lawful purposes described in this Privacy Policy and the applicable Terms and Conditions.
34. Aggregated, Statistical and Anonymized Information
Tathmeer may create aggregated, statistical, de-identified, pseudonymized, or anonymized information from information collected through the Services.
Such information may be used for purposes including analytics, research, benchmarking, agricultural insights, service development, operational analysis, business planning, performance measurement, reporting, and improvement of Tathmeer’s products and Services.
Where such information is genuinely anonymized and cannot reasonably be used to identify an individual, it may be retained and used by Tathmeer for legitimate purposes notwithstanding deletion of an individual’s account or Personal Data, subject to applicable law.
35. Artificial Intelligence Service Providers and Model Processing
Certain Tathmeer AI features may rely upon third-party infrastructure, models, APIs, platforms, or other artificial intelligence technologies.
Depending on the relevant implementation, information submitted through an AI feature may be transmitted to a third-party AI service provider for processing on behalf of Tathmeer.
Tathmeer will seek to configure and contractually govern such services in a manner consistent with applicable legal requirements and the intended purpose of the relevant feature.
The precise processing performed by an AI provider may depend on the particular technology, configuration, service terms, security architecture, and integration used by Tathmeer at the relevant time.
Users should avoid submitting information through AI features that they do not have authority to disclose or that they do not wish to be processed for the relevant purpose.
36. Third-Party Websites and Services
The Services may contain links, integrations, references, or connections to websites, applications, platforms, services, or resources operated by third parties.
Tathmeer does not control the privacy practices, security practices, content, or policies of independent third parties.
When users access a third-party service, the third party’s privacy policy and terms may apply. Users are responsible for reviewing the relevant third-party policies before providing Personal Data or using the third-party service.
38. User Security Responsibilities
Users are responsible for maintaining the confidentiality of their account credentials and for taking reasonable measures to protect access to their accounts and devices.
Users must promptly notify Tathmeer if they suspect unauthorized access to their account, loss or theft of credentials, or other activity that may compromise the security of their account or Personal Data.
Users must not share passwords, authentication codes, access tokens, or other security credentials with unauthorized persons.
39. Privacy by Design and Internal Governance
Tathmeer seeks to incorporate appropriate data-protection principles into its technology, operational processes, vendor-management procedures, product development, and business practices.
Depending on the nature of a processing activity, Tathmeer may maintain internal records concerning the categories of Personal Data processed, processing purposes, data sources, recipients, retention periods, security measures, processing locations, third-party providers, and applicable legal requirements.
Tathmeer may also conduct privacy or security assessments where the nature, scale, sensitivity, or risk associated with a processing activity reasonably requires such assessment.
40. Records and Auditability
Tathmeer may maintain appropriate records relating to Personal Data processing, consent, privacy requests, security incidents, data retention, third-party processing, cookies and tracking technologies, and other privacy-related activities where required or appropriate.
Such records may be maintained for compliance, audit, security, governance, operational, legal, or regulatory purposes.
41. Privacy Incidents and User Notification
Where a privacy incident affects Personal Data, Tathmeer will assess the incident and take reasonable steps to investigate, contain, remediate, and prevent recurrence.
Where applicable law requires notification to an affected individual or authority, Tathmeer will provide such notification within the applicable timeframe and in the manner required by law.
42. Changes to This Privacy Policy
Tathmeer may amend or update this Privacy Policy from time to time to reflect changes in the Services, technology, business operations, legal requirements, regulatory expectations, or privacy practices.
Where changes are material, Tathmeer may provide an appropriate notice through the website, mobile application, email, account notification, or another reasonable communication mechanism.
The updated Privacy Policy will become effective on the date stated in the updated version unless otherwise required by applicable law.
Users are encouraged to review this Privacy Policy periodically to remain informed about how Tathmeer processes Personal Data.
43. Governing Law
This Privacy Policy shall be governed by and interpreted in accordance with the applicable laws of the United Arab Emirates.
Any matter relating to the interpretation, implementation, enforcement, or application of this Privacy Policy shall be subject to the applicable laws and jurisdictional requirements of the United Arab Emirates, without prejudice to any mandatory rights or protections available to individuals under applicable law.
44. Privacy Contact
For questions, requests, complaints, or concerns relating to Personal Data, privacy, data protection, cookies, AI-related processing, or the exercise of applicable data-protection rights, users may contact:
Tathmeer Compliance Manager — Email: support@tathmeer.ai
Users should provide sufficient information to allow Tathmeer to understand and appropriately respond to the request.
45. Complaints and Concerns
Tathmeer encourages users to contact the Tathmeer Compliance Manager in the first instance if they have concerns regarding the processing of their Personal Data or the implementation of this Privacy Policy.
Tathmeer will review privacy complaints and concerns in accordance with its internal procedures and applicable legal requirements.
Nothing in this section limits an individual’s right to approach a competent regulatory authority or exercise any other right available under applicable law.
46. Effective Date and Periodic Review
This Privacy Policy is effective from the date stated at the beginning of this document and will remain in effect until replaced or withdrawn by Tathmeer.
Tathmeer may periodically review this Privacy Policy to ensure that it remains consistent with its Services, technology environment, data-processing activities, contractual arrangements, and applicable legal requirements.
