You entrust us with your information when you use our products and services. We realize that this is a great responsibility, so we are keen to work hard to protect your information by the GDPR and give you full control over it. At the same time, we provide you with various services through this site, and we reserve all ownership rights to them and adhere to their terms of use.

Khutana E-Marketing realizes the importance of privacy and protection of personal data in our digital age, and therefore we are committed to protecting the privacy of users of Khutana E-Marketing services while browsing or using our websites and our services. The Privacy Policy and Terms of Use (“Privacy Policy” – “Terms of Use”) will explain how Khutana E-Marketing guarantees the protection of personal data to a very large extent (such as any information relating to natural persons who can be identified, directly or indirectly, in particular by reference to an identification feature such as a name, identification number, location information, online identifier, or one or more factors specific to that natural person; hereinafter referred to as “Personal Data”). In addition to the terms of use of services, products, resources, benefits, and the like.

Specifically, the Privacy Policy will explain:

• Why we collect and process your personal and general data protection data;

• On what legal basis do we process your data;

• Who can access your data and the information collected;

• Where your data may be stored or transferred;

• How we protect the security of your data under the General Data Protection Regulations;

• How long we retain your data;

• How to access, update, and delete your data;

• How we use cookies;

• How the Privacy Policy applies to third-party data processing such as Apple of personal data;

The Privacy Policy and Terms of Use apply to all services offered and provided by Khutana E-Marketing on its websites, digital applications, competitions, and other digital properties (“Khutana E-Marketing Services”). Other special notices may also be sent highlighting specific uses we wish to make of your data as well as the ability to opt in or opt out of specific uses on a case-by-case basis, including new services or other services that may have their privacy policy and terms of use.

Please note that in some countries you must be 18 years or older to subscribe to our e-marketing services, the age of majority may be greater than 18 years, in which case you must reach that age to subscribe. While individuals under the age of 18 may benefit from our e-marketing services, they may only do so with the involvement, supervision, and consent of a parent or legal guardian.

Key Definitions for the Privacy Policy and Terms of Use:

“I”, “us”, or “we” refers to our e-marketing services. “You”, or “User” refers to the person(s) using our e-marketing services.

Privacy Policy

Why do we collect and process your personal and general data protection data?

We collect and process your data for the following purposes:

• To provide you with the services you request from us; To allow you to use online forms and surveys, including our e-marketing services that do not require any form of registration; To allow you to sign up for certain services, such as newsletters, information feeds, or SMS updates, or to create an account, in which case we will ask for personal data such as your name, email address, or phone number.

• To allow you to share information; To allow you to take full advantage of the sharing features we offer, such as participating in viewer forums, social media, discussion boards, and interacting with second screen applications for shared viewing; To allow you to create a publicly viewable profile on Khutana E-Marketing, which may include, if you choose, your name and photo; To combine your personal information we obtain through one service with information we collect from other services provided by Khutana E-Marketing to make it easier to share things with people you know.

• To maintain and improve our services; To understand how you use Khutana E-Marketing services and implement other functions; and To develop new services and offers.

• To provide services tailored to your needs and interests; To provide you with personalized content such as advertisements and related services; To allow us to get to know you better to provide you with more of the services you request, more offers, exclusive offers, information and competitions, and to give you a better user experience; and to discover more complex things such as which advertisements you may find most useful or which services and information are most relevant to you, giving you a better and more useful experience of our digital properties.

• To carry out payment transactions; to store a record of transactions; to ensure that you pay for your subscription fees for our services or quotes and the cost of the services; and to comply with a legal or regulatory obligation in this regard.

• To communicate with you; to allow you to contact Khutana E-Marketing; to keep a record of our conversations; to help you resolve any issues you may have; to send you promotions and direct marketing; to inform you about our services such as providing you with information about upcoming programs or adding modifications to our digital properties; and to contact you to compete and participate in various offers.

• To create and maintain a reliable and secure environment; to investigate, detect, prevent, or report fraud, misrepresentations, violations, security incidents, or other potentially prohibited or illegal activities; and to protect our vendors, your rights, and the security and integrity of our services; To enforce our Terms of Service or other agreements or policies; and to verify your identity.

• To comply with any laws By applicable laws or regulations; or to respond to legal requests for information from the government or through legal process; and to fulfill any other purpose disclosed to you in connection with our Services, and to contact you to resolve disputes and provide assistance with our Services.

On what legal basis do we process your data?

Depending on the type of data to be processed, we will process your data on one of the following grounds:

• Your prior consent: For example, when we offer you to register for our Services and create an account for you or subscribe to our newsletters or marketing emails or when we ask you to follow any relevant procedure that allows you to either accept or refuse the processing of the data; if you accept, you have the right to withdraw your consent at any time. However, in some cases, your choice not to disclose your data or to withdraw your consent may limit your use of our Services, features, or offerings. For example, you may not be able to access certain parts of our websites and respond to your inquiries without providing the relevant information.

• Contractual relationship: In such a case, the processing of your data is generally necessary for the performance or fulfilment of a contract; This means that if you do not want us to process your data in this context, we may refuse to enter into such a contract with you.

• Legitimate interest: In the sense of data protection law: for example when monitoring or tracking devices are applied that indicate the processing of personal data to detect and prevent online fraud and intrusion. For example, when you access and visit our websites, even without creating an account, and make use of the services provided by Khutana E-Marketing and/or Khutana E-Marketing digital properties, you acknowledge that we may carry out legitimate data processing as described in the Privacy Policy and Terms of Use. If you do not agree to the Privacy Policy and Terms, you may wish to stop viewing/using our websites.

• Legal obligations applicable to our activities from all parties including the Ministry of Human Resources and Social Development.

Who can access your data and the information collected:

For the purposes described above, we will provide access to your data to authorized employees of our e-marketing line and members of our e-marketing line who need to know that information to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or even terminated if they fail to comply with these obligations or the Privacy Policy.

In addition, we may need to transfer or allow authorized third parties to access your data, namely:

• Suppliers and service providers who we engage to process personal data or perform our e-marketing line services on our behalf (based on our instructions and by our Privacy Policy and other appropriate security and confidentiality measures);

• Successors in ownership of the company or our business (or in serious discussions about such possibility with the new (potential) owners of the business or company); In this regard, if the ownership of the Company or all or substantially all of our business changes or a corporate reorganization or other transaction or transfers between entities affiliated with our e-marketing plan, you acknowledge and accept that we may need to transfer your data to the relevant third party (or consultants) as part of any process to analyze any proposed sale or reorganization of the new owner. We may also need to transfer your data to such reorganized entity or third party after the sale or reorganization of your data for the same purposes as described in this Privacy Policy;

• Our media representatives;

• Legal advisors, witnesses, experts, judicial and quasi-judicial authorities to protect the Group from any harm to its rights, property, or safety, to protect our users or the public and any third party as required or permitted by law, and to enforce the terms of our services, including investigating potential violations;

• Administrative or judicial authorities to meet the requirements of any applicable law, regulation, legal process, or enforceable governmental request.

• We may also collect anonymous data from the public third parties and other authorized partners – such as advertising companies or linked sites. For example, we may share information publicly to provide indicators of the general use of our services.

Where is your data stored or transferred?

Our e-marketing business is part of an international group with subsidiaries, partners, and contractors located in many countries around the world. For this reason, we may need to transfer your data to other countries, including outside the European Economic Area, and to countries where data protection laws may be weaker than those in your country. For example, we may process your data on a server located outside the country in which you reside and for this purpose, we may transfer your data outside your country of residence. To ensure an adequate and consistent level of protection for your data, we will continue to implement appropriate safeguards to protect your data on an ongoing basis. For further information, please contact us as described in the “How to contact us” section at the end of this Privacy Policy.

How do we protect the security of your data under the GDPR?

We maintain appropriate physical, electronic, technical, security, and organizational measures, including governance models, to protect your data by data protection law from unauthorized access, use, alteration, disclosure, or destruction of personal data. Please note that no data transmission over the Internet or the Website can be guaranteed to be uninterrupted. In addition, you must also take appropriate steps to protect your data, especially by keeping your password and its confidentiality.

If you know or suspect that your account credentials have been lost, stolen, misappropriated, or otherwise compromised, or if there has been any unauthorized use of your account, please contact us by following the instructions in the “How to Contact Us” section below at the end of the Privacy Policy page. If we know or have reason to believe that your data has been compromised, we will promptly notify affected users of the breach by applicable laws in the Privacy Policy.

How long do we retain your data?

We will retain your data for as long as your account is active, or as long as is necessary for the purpose for which the data was originally collected. This retention period may be up to 10 years. Our retention periods are based on the needs of our business, and your information that is no longer needed is permanently anonymized or destroyed. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. For this reason, after deleting information from our Services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems. We may also retain your data for longer periods if necessary to comply with our legal obligations or to protect our legitimate interests.

How to access, update, and delete your data?

Under data protection law you are entitled to exercise the following rights:

• The right to access your data, in which case we may provide you with a copy of that data, if it is not directly available to you, for example within your account;

• The right to rectify your data, if your data is inaccurate or outdated; in this regard, it is important that the personal data we hold about you is accurate and up-to-date. Please inform us if there has been any change to your data during the period in which we hold your information;

• The right to withdraw consent, where processing is based on your prior consent and to withdraw your consent to all marketing;

• The right to object to the processing of your data, where processing is based on our legitimate interests, to the extent your situation allows;

• The right to have your data erased;

• The right to restrict the processing of your data;

• The right to have your data transmitted to a third party or to have your data transmitted to a third party of your choice where technically feasible;

• The right to complain to a data protection authority if you consider that the processing of your data has violated data protection law.

• You may submit a request to us regarding these matters at any time as set out in the “How to Contact Us” section at the end of this Privacy Policy page.

Please note that:

• We may need to verify your identity before we act on your request;

• As the exercise of these rights is subject to certain legal conditions and restrictions, we may have to refuse your request if these conditions are not met or if there are legal restrictions;

• We may refuse unreasonably repetitive requests, require technical effort (for example, developing a new system or fundamentally changing existing practices), or pose a risk to the privacy of others.

• In any event, we will endeavor to deal promptly with your request within one month (subject to any extensions we may legally obtain). If we reject your request, we will tell you the reasons by our Privacy Policy.

How do we use cookies?

A cookie is a small piece of information that a web server sends to a web browser, allowing the server to collect information from the browser. Most browsers allow you to turn off cookies. If you want to know how to do this, please see the help menu on your browser. However, some cookies are necessary for us to provide you with the Khutana E-Marketing services you have requested, and turning off cookies will limit your use of our digital properties.

For example, we store and use cookies and similar technologies:

• To improve your user experience and ensure the overall quality of Khutana E-Marketing services;

• To recognize you when you visit our digital websites;

• To track and study your browsing and navigation patterns on the website, to create your demographic profile, and to provide you with the service most appropriate to your taste (more relevant recommendations and offers related to what you like);

• To analyze your content consumption habits (e.g., programs viewed, content read, devices used, etc.) and to provide, personalize, measure,e and improve our advertising and marketing;

• To deliver appropriate content that is permitted in each geographic area based on the intellectual property rights licensed to us;

• To share certain data to provide personalized advertising to you and to send marketing materials and newsletters.

We also share information about your use of our site with our social media, advertising, and analytics partners who may combine it with other information you have provided to them or that they have collected from your use of their services. By using our services, you agree to our cookies. To learn more about how we use cookies, please contact us as described in the “How to Contact Us” section at the end of this Privacy Policy.

How to delete cache, cookies, logs, and passwords from browsers such as Google Chrome

How does this Privacy Policy apply to third-party data processing such as Apple for personal data?

Our e-marketing services may be provided through and/or utilize features (such as voice controls) operated by third-party platforms, or contain links to sites operated by third parties whose policies regarding the processing of personal data may differ from ours.

For example:

• You may be able to access the Services Our e-marketing services are delivered through platforms such as gaming consoles, smart TVs, mobile devices, set-top boxes, and other internet-connected devices. In addition, you may encounter third-party applications that interact with our e-marketing services. These third parties have separate and independent privacy and personal data policies.

• Our digital sites may contain links to other websites that are outside our control and are not covered by this Privacy Policy. If you access other websites through the available links, the operators of those websites may collect and use information from you by their privacy policies, which may differ from ours.

We invite you to review these policies and terms if you wish to inquire about the processing of your data by a third party.

How to contact us?

If you have any other questions, please contact us at the following email: info@khutana.com or book a meeting.

How can the Privacy Policy be updated?

We may update the Privacy Policy from time to time in response to legal, regulatory, or operational requirements. Any changes to the Privacy Policy will be posted on this page. Where such changes are material, we may provide you with specific notice of any such changes (including when they will take effect) by the law. We may not notify you of any updates or changes to the Privacy Policy. Where applicable (for example, if the changes require new data processing based on your prior consent) we will ensure that you are allowed to accept such changes so that you can continue to use our Services or decline them – in which case you have the right to cancel your use of our Services.

The privacy policy was last updated on 1 January 2025.