Adoohy Platform & Technologies Ltd Privacy Policy
Effective Date: 11 November 2025
Jurisdiction: Dubai International Financial Centre (DIFC), United Arab Emirates
1. Introduction
Adoohy Platform & Technologies Ltd (“Adoohy”, “we”, “us”, or “our”) respects your privacy and is committed to protecting the personal information you share with us.
This Privacy Policy (“Policy”) outlines how we collect, use, disclose, store, and protect personal data when you interact with our platform, mobile applications, website, and related services (collectively, the “Platform” or “Services”).
This Policy complies with DIFC Data Protection Law No. 5 of 2020 (the “DP Law”), Dubai and UAE data protection regulations, and, where applicable, international data protection standards.
By using the Platform, you acknowledge and consent to the practices described in this Policy.
2. Scope and Application
This Policy applies to all individuals and entities (“Users”) who access, browse, register, or otherwise interact with the Adoohy Platform, whether as advertisers, media owners, agencies, or visitors. This Policy governs Adoohy’s data processing activities within the DIFC and the wider UAE, including transfers to and from other jurisdictions, where permitted by applicable law.
3. Information We Collect
A. Information You Provide to Us
We collect information you provide directly through our Platform or via communication channels (email, phone, chat, or otherwise), including:
Identity Data: Name, company name, title, address, email, phone number, and contact details.
Account Data: Username, password, account preferences, and profile information.
Business Data: Campaign information, media inventory details, financial or billing information, VATregistration details, and transaction records.
Communications: Records of your correspondence, feedback, and queries submitted throughsupport or contact channels.
You are responsible for ensuring that any data you provide is accurate and up to date.
B. Information Collected Automatically
When you access or use the Platform, we may automatically collect:
Device Information: Device type, operating system, browser type, time zone, and IP address.
Usage Data: Log files, browsing actions, interaction metrics, access times, and viewed pages.• Location Data: Approximate geolocation derived from your IP address or device settings (if enabled).
This information helps us optimize performance, security, and user experience.
C. Information from Third Parties
We may receive information about you from third parties, including:
Advertising networks, analytics providers, and campaign measurement tools.
Business partners, service providers, or publicly available sources.
Government registries and compliance databases, where legally permitted.
4. Purpose and Legal Basis for Processing
We process Personal Data under the following lawful bases, as permitted by the DIFC DP Law and UAE Federal Decree-Law No. 45 of 2021:
To operate, manage, and improve our Platform and Services — Legitimate interest / contractualnecessity.
To verify user identity, enable account access, and process transactions — Contractual necessity.
To comply with regulatory, financial, and anti-fraud obligations — Legal obligation.
To send operational, administrative, and service-related communications — Legitimate interest.
To send marketing communications (with consent) — Consent.
To analyze user trends and improve user experience — Legitimate interest.
To respond to enquiries and support requests — Contractual necessity.
We will not process Personal Data in a way that is incompatible with the purposes for which it was collected unless legally required.
5. Data Sharing and Disclosure
Adoohy may share your Personal Data only under strict legal and contractual safeguards, as follows: • Within Adoohy Group: Among subsidiaries, affiliates, or related entities for internal operations, analytics, and compliance.
Service Providers: With trusted third-party vendors (IT hosting, analytics, payment gateways, etc.)under binding confidentiality and data protection terms.
Regulatory and Legal Authorities: When disclosure is required by law, court order, or to comply withDIFC or UAE governmental requests.
Business Transactions: In connection with mergers, acquisitions, financing, or asset transfers,subject to confidentiality safeguards.
Anonymized Data: We may share aggregated or anonymized data that cannot reasonably identifyyou.
We do not sell or rent your Personal Data to third parties.
6. International Transfers
Your Personal Data may be transferred and stored outside the DIFC or UAE. Where this occurs, Adoohy ensures appropriate adequacy decisions, contractual safeguards, and technical protections are implemented, in line with Article 26 of the DIFC DP Law.
7. Data Retention
We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, or enforce agreements. Retention periods may differ based on regulatory, tax, or audit requirements.
8. Security of Personal Data
We implement appropriate technical and organizational measures to protect your Personal Data from unauthorized access, disclosure, alteration, or destruction, including:
Data encryption and secure transmission (SSL/TLS).
Controlled access to data and systems on a need-to-know basis.
Regular penetration testing and data protection audits.
Secure cloud infrastructure hosted in ISO 27001-certified environments.
Staff confidentiality agreements and training in data protection.
While we take all reasonable precautions, no online transmission can be guaranteed as completely secure.
9. Your Rights
Under the DIFC DP Law and applicable UAE laws, you have the following rights:
Access — request a copy of the Personal Data we hold about you.
Rectification — request correction of inaccurate or incomplete data.
Erasure — request deletion of data when legally permissible.
Restriction — limit processing under certain conditions.
Portability — receive your Personal Data in a structured, commonly used format.
Objection — object to processing based on legitimate interests or direct marketing.
Withdrawal of Consent — where processing is based on consent, you may withdraw it at any time.To exercise these rights, please contact our Data Protection Officer at privacy@adoohy.com.
10. Cookies and Tracking Technologies
Adoohy uses cookies and similar technologies to enhance functionality, measure performance, and personalize your experience. Cookies may include:
Essential Cookies — necessary for site functionality and login.
Analytics Cookies — to understand how users interact with our Platform (e.g., Google Analytics).
Advertising Cookies — to measure campaign effectiveness and retarget users with relevant ads.You can manage cookie preferences in your browser settings or through our cookie consent tool.
11. Marketing and Communications
We may send you promotional or service-related communications via email, SMS, or app notifications. You may opt out at any time by using the unsubscribe link in the message or by contacting us directly. Please note that operational or transactional messages cannot be opted out of as they are necessary for the provision of services.
12. Children’s Privacy
Adoohy’s Platform is not intended for use by children under 18 years of age. We do not knowingly collect or process children’s personal data. If we become aware of such collection, we will promptly delete it.
13. External Links
Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices or content of those third parties, and this Policy does not apply to their data processing activities. We encourage you to review their privacy policies before engaging with them.
14. Changes to This Policy
We may update this Policy periodically to reflect changes in law or operational practices. Updated versions will be posted on our website with the revised “Effective Date.” Your continued use of the Platform after changes are published constitutes your acceptance of the updated Policy.
15. Data Protection Officer and Contact Information
Adoohy Platform & Technologies Ltd has appointed a Data Protection Officer (DPO) in accordance with Article 16 of the DIFC DP Law.
If you have questions, complaints, or requests concerning your personal data, please contact:
Data Protection Officer
Adoohy Platform & Technologies Ltd
Dubai International Financial Centre (DIFC), Dubai, UAE
Email: privacy@adoohy.com
If you are unsatisfied with our response, you may contact the Commissioner of Data Protection, DIFC at commissioner@dp.difc.ae for further assistance.
16. Governing Law
This Policy and any dispute arising from it shall be governed by and construed in accordance with the laws of the Dubai International Financial Centre (DIFC) and, where applicable, the laws of the United Arab Emirates, without prejudice to mandatory provisions of applicable data protection regulations.
Compliance Note
This Privacy Policy is drafted to align with: DIFC Data Protection Law No. 5 of 2020; UAE Federal Decree-Law No. 45 of 2021 (Personal Data Protection Law); Dubai Digital Authority compliance obligations; and ISO 27001/GDPR-equivalent principles where appropriate.
Adoohy Platform & Technologies Ltd · Dubai International Financial Centre (DIFC), Dubai, UAE · privacy@adoohy.com