Privacy Policy

Owner and data controller

The Dream Draw Platform collects Personal Data from its Users

DREAM DRAW L.L.C.-FZ

U.A.E. Address: Business Center 1, M Floor, Al Meydan Hotel, Meydan Free Zone, Nad Al Sheba, Dubai, United Arab Emirates. Tel: +971 4 397 4070

DPO ContactZ

U.A.E. Address: Business Center 1, M Floor, Al Meydan Hotel, Meydan Free Zone, Nad Al Sheba, Dubai, United Arab Emirates. Tel: 971 4 397 4070

Legal information

Definitions and Interpretation

In this Privacy Policy:

1. All capitalised words and expressions used shall have the following meanings; and
2. Unless the context otherwise requires, words in the singular shall include the plural and, in the plural, shall include the singular.

Types of data collected

Among the types of Personal Data that this Platform collects, by itself or through third parties, this can be broadly categorised as email address, Usage Data, first name, last name, telephone number, Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and geographic position. Complete details on each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy or by specific explanation texts displayed prior to the Data collection

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using the Platform. Unless specified otherwise, all Data requested by the Platform is mandatory. Failure to provide this Data may make it impossible for the Platform to provide its Services. In cases where the Platform specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies, or of any other tracking tools, by this Platform or by the owners of third-party services used by this Platform, serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy. Users are responsible for any third-party Personal Data obtained, published, or shared through this Platform and confirm that they have the third partys consent to provide the Data to the Owner.

Data Processing

Methods of Processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. Data Processing is carried out using computers and/or IT-enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain persons involved with the operation of the Platform (such as but not limited to: administration, sales, marketing, legal, and system administration) or external parties (such as but not limited to: third party technical service providers, mail carriers, hosting providers, IT companies and communications agencies) appointed, if necessary, as Data Processors by the Owner. An updated list of these parties may be requested from the Owner at any time.

Legal Basis of Data Processing

The Owner may process Personal Data relating to Users if any one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations, the Owner may be allowed to process Personal Data until the User objects to such Data Processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• Processing is necessary for compliance with a legal obligation to which the Owner is subject;
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will help to clarify the specific legal basis that applies to the Data Processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

Data Processing is carried out at the Owners operating offices and in any other places where the parties involved in the Data Processing are located. Depending on the Users location, data transfers may involve transferring the Users Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can refer to the section “Detailed information on the Processing of Personal Data”. Users are also entitled to learn about the legal basis of Data transfers to a country outside of the European Union, or to any international organisation governed by public international law or set up by two or more countries (such as the UN), and about the security measures taken by the Owner to safeguard their Personal Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this Privacy Policy or inquire with the Owner using the information provided in the contact section.