Privacy Policy

A. This Policy

This Policy explains how we Process Personal Data. This Policy may be amended or updated from time to time, so please check it regularly for updates. This Policy is issued by DebloMassi which is made up of each of the Controller entities ("DebloMassi", "we", "us" and "our") and is addressed to individuals outside our organisation with whom we interact in our course of business as a Merchant of Record, including customers, visitors to our Sites, other users of our products or services, personnel of corporate customers and vendors, applicants for employment, and visitors to our premises (together, "you").

Please note that not all provisions of this Policy will apply to you and your Personal Data, as this will depend on your specific relationship with DebloMassi.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

B. Collection of Personal Data

Summary: We collect or obtain Personal Data: when that data is provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you appoint us as your Merchant of Record or if you make a purchase from DebloMassi); when you make Personal Data public (e.g., if you make a public post about us on social media); when you visit our Sites; when you register to use any of our Sites, products, or services; or when you interact with any third party content or advertising on a Site; we may also receive Personal Data about you from third parties (e.g., law enforcement authorities).

We collect or obtain Personal Data about you from the following sources:

• Data provided to us: We obtain Personal Data when such data is provided to us (e.g., where you contact us via email or via our Sites, or by any other means, or when you provide us with your business card, or when you submit a job application).
• Data we obtain in person: We obtain Personal Data during meetings, at trade shows, during visits from sales or marketing representatives, in person interviews or at events we attend.
• Collaborations: We obtain Personal Data when you collaborate with us in research or in an advisory/consultancy capacity.
• Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g. we provide a service to you, or to your employer).
• Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media.
• Site data: We may collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
• Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites, products, or services.
• Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

C. Creation of Personal Data

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, products, or services, including where that data is collected from different sources.

D. Categories of Personal Data we Process

We Process the following categories of Personal Data about you:

• Personal details: given name(s); preferred name.
• Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
• Contact details: correspondence address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
• Consent records: records of any consents you have given, together with the date and time; means of consent and any related information.
• Purchase details: records of purchases and prices; and consignee name, address, contact telephone number and email address.
• Payment details: invoice records; payment records; billing address; payment method; cardholder or account holder name; card payment identifiers; payment amount; and payment date.
• Data relating to your use of our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; and usage data.
• Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
• Transaction record: for every purchase we capture and retain the full order record — product, amount, currency, time — together with your email address, billing details, IP address, the country that IP resolves to, device and browser characteristics (a device fingerprint), the language of your browser, the authentication result, the masked card details described in section I, and the proof that the digital product was delivered. We need this to deliver the purchase, to defend a chargeback or a fraud claim with evidence rather than assertions, and to meet our obligations to payment schemes and regulators. The country data is also what enforces the geographic restrictions in our Terms: an order from a country we do not serve is refused before a payment is created.

E. Sensitive Personal Data

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business as a Merchant of Record. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

• Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law.
• Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime.
• Establishment, exercise or defence of legal claims: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal claims.
• Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing.

F. Purposes of Processing and Legal Bases for Processing

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

• Provision of Sites, products, and services: providing our Sites, products, or services; providing promotional items upon request; and communicating with you in relation to those Sites, products, or services.
• Compliance checks: fulfilling our regulatory compliance obligations; 'Know Your Client' checks; and confirming and verifying your identity.
• Operating our business: operating and managing our Sites, our products, and our services; providing content to you; displaying advertising and other information to you.
• Communications and marketing: communicating with you via any means to provide news items and other information in which you may be interested.
• Management of IT systems: management and operation of our communications, IT and security systems; and audits of such systems.
• Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises.
• Financial management: sales; finance; corporate audit; and vendor management.
• Surveys: engaging with you for the purposes of obtaining your views on our Sites, our products, or our services.
• Security: physical security of our premises; CCTV recordings; and electronic security.
• Investigations: detecting, investigating and preventing breaches of policy, and criminal offences.
• Legal compliance: compliance with our legal and regulatory obligations under applicable law.
• Fraud prevention: Detecting, preventing and investigating fraud.

G. Disclosure of Personal Data to Third Parties

We disclose Personal Data to other entities within the DebloMassi group, for legitimate business purposes and the operation of our Sites, products, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to:

• You and, where appropriate, your appointed representatives
• Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation
• Accountants, auditors, consultants, lawyers and other outside professional advisors to DebloMassi
• Third party Processors (such as payment services providers etc.)
• Any relevant party, regulatory body, governmental authority, law enforcement agency or court
• Suppliers to the extent necessary to provide a product requested by you
• Our payment service providers, which process the card payment itself and settle the funds to us
• The regulated disbursement providers we use to pay merchants — currently Wise, VaultLeap, Dollafy and GetHEVN — which receive only the payout data of the merchant being paid, never buyer data
• Card schemes, acquirers and issuing banks, where a chargeback or fraud claim requires us to submit the evidence we hold for the disputed transaction

H. International Transfer of Personal Data

Because of the international nature of our business, we transfer Personal Data within the DebloMassi group, and to third parties as noted above, in connection with the purposes set out in this Policy. For this reason, we may transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

I. Data Security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing.

Payment card data. Card details are entered on, and processed by, payment service providers certified under the Payment Card Industry Data Security Standard (PCI DSS). DebloMassi does not receive or store full card numbers, and no card verification value (CVV) is ever stored. Our records hold only the card brand, the first six and last four digits, the expiry and the result of the authorisation — enough to identify a payment on a receipt or in a dispute, and nothing more. Access to our systems is restricted, logged and reviewed, and administrative access requires two-factor authentication.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk.

J. Data Accuracy

We take reasonable steps to ensure that:

• Your Personal Data that we Process is accurate and, where necessary, kept up-to-date
• Any of your Personal Data that we Process that is inaccurate (having regard to the purposes for which it was Processed) is erased or rectified without delay

K. Data Minimisation

We take reasonable steps to ensure that your Personal Data that we Process is limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

L. Data Retention

We take reasonable steps to ensure that your Personal Data is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data includes maintaining an ongoing relationship with you, legal obligations, and applicable limitation periods.

In practice: the transaction record described in section D is kept for as long as the tax, accounting and payment-scheme rules require, and at least until the chargeback window for that payment has closed — up to 120 days after the sale, and longer where a dispute, a fraud investigation or a legal claim is open. When both the purpose and the retention period have ended, the data is deleted or irreversibly anonymised.

M. Your Legal Rights

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• The right not to provide your Personal Data to us
• The right to request access to, or copies of, your Relevant Personal Data
• The right to request rectification (or correction) of any inaccuracies in your Relevant Personal Data
• The right to request, on legitimate grounds: erasure of your Relevant Personal Data or restriction of Processing
• The right to have certain Relevant Personal Data transferred to another Controller
• The right to withdraw consent
• The right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority

N. Cookies and Similar Technologies

When you visit a Site we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits.

O. Direct Marketing

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, products, or services that may be of interest to you. You may unsubscribe for free at any time.

You may change your preferences, or unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication and updating your communication preferences.

P. California Consumer Privacy Act Disclosures

Under the California Consumer Privacy Act as amended ("CCPA"), we must disclose our practices regarding the collection, use, and disclosure of the Personal Information of California Residents ("Consumers"). Consumers are also afforded additional rights with regard to the Personal Information that we collect about them that include the rights of access, deletion, and to be free from discrimination.

We do not Sell any Personal Information to third parties. In particular, we do not Sell the personal information of minors under 16 years of age.

Q. Saudi Arabia — Personal Data Protection Law (PDPL)

This section applies to individuals in the Kingdom of Saudi Arabia and is provided under the Personal Data Protection Law and its Implementing Regulations, supervised by the Saudi Data and Artificial Intelligence Authority (SDAIA). It is published here so that you can read it before your Personal Data is collected. Where it differs from the rest of this Policy, this section governs for individuals in the Kingdom.

Who is responsible. DebloMassi Inc. is the Controller of the Personal Data described in this Policy. Contact details are in section S.

Why we collect Personal Data (purpose). To sell and deliver the digital product you buy as Merchant of Record; to take and settle payment; to issue receipts and tax invoices; to prevent, detect and investigate fraud and abuse; to handle refunds, chargebacks and complaints; to meet our obligations under tax, accounting, anti-money-laundering and payment-scheme rules; to operate, secure and improve our platform; and, only with your consent, to send you marketing.

What we collect (content). Your name and contact details; the order and its price; payment details limited to the payment method, the card brand and the first six and last four digits of the card, the authorisation result and the payment reference; the email address you paid with; technical data such as IP address, device, browser and the time of your connection; your messages to our support; and, for merchants, the business, identity and settlement information required to open and operate an account. Section D lists the categories in full.

How we collect it (method). Directly from you when you buy, register, verify your email or write to us; automatically from your device when you use our sites and checkout, including through cookies (section N); from the merchant whose product you bought; and from our payment service providers, banks and fraud-prevention partners in connection with your payment.

How we store it (means of storage). In access-controlled databases and backups operated for us by reputable cloud infrastructure providers, encrypted in transit and at rest, and, in the case of documents you upload, encrypted at rest and readable only by authorised staff for the purpose of reviewing your application or dispute.

How we process it. By our own authorised personnel on a need-to-know basis, and by processors acting on our documented instructions — payment service providers, email delivery, cloud hosting, fraud screening and professional advisers. We do not sell Personal Data, we do not use it to train third-party artificial-intelligence models, and we do not make decisions producing legal effects about you by automated means alone; automated fraud screening may flag a payment for review by a person.

Legal bases. Performance of the contract you enter when you buy or open an account; compliance with a legal obligation; our legitimate interests in securing the platform and preventing fraud, where those interests do not override your rights; and your consent, which you may withdraw at any time, for marketing and for non-essential cookies.

How long we keep it, and how it is destroyed. We keep Personal Data only as long as the purpose requires. Transaction, invoice and tax records are kept for the retention period required by tax, accounting and payment-scheme rules, and records connected to fraud, disputes or a legal claim are kept until the matter and any limitation period has ended. When the purpose and the retention period have both ended, the data is deleted from our live systems and from backups on their normal expiry cycle, or is irreversibly anonymised so that it can no longer be linked to you.

Transfers outside the Kingdom. Our platform, our payment service providers and some of our processors operate outside Saudi Arabia, so your Personal Data may be transferred and processed abroad. We transfer it only where it is necessary for the purposes above, we limit it to what the purpose needs, and we require the recipient by contract to protect it to the standard set out in this Policy and to use it only for our instructions. Transfers are assessed as required by the PDPL and its transfer regulations, and we do not transfer Personal Data where that would prejudice the Kingdom's national interests.

Your rights, and how to exercise them. Under the PDPL you have the right to be informed of the legal basis and purpose of collection; to request access to your Personal Data; to obtain a copy in a readable, portable format; to request correction, completion or update; to request destruction of Personal Data that is no longer needed; and to withdraw a consent you gave. To exercise a right, write to payments@deblomassi.com from the email address concerned, or with enough detail for us to identify you. We may ask for information to verify your identity before we act, we do not charge for a request, and we answer within thirty (30) days. If we cannot act on a request, we tell you why.

Marketing. We send marketing only where you have opted in, we never use sensitive data for marketing, and every marketing message carries a one-click unsubscribe. Service messages about a purchase, a receipt, a security event or your account are not marketing and are sent regardless.

Data breaches. If Personal Data is leaked, damaged or accessed without authorisation, we notify SDAIA within seventy-two (72) hours of becoming aware of the incident, and we notify affected individuals without undue delay where the incident poses a serious risk to their data or to them.

Children. Our Services are not directed at children. We do not knowingly collect Personal Data from anyone under 18; if you believe a minor has provided us with data, write to us and we will delete it.

Complaints. Write to us first at payments@deblomassi.com — we acknowledge within five (5) business days. If you are not satisfied, you may complain to the Saudi Data and Artificial Intelligence Authority (SDAIA), the competent supervisory authority for the PDPL.

R. ملخص سياسة الخصوصية باللغة العربية

S. Contact Information

For questions about this Privacy Policy, or to exercise a right over your Personal Data, please contact us at:
Email: payments@deblomassi.com

Service provider

DebloMassi Inc.

Website

deblomassi.com

Email

payments@deblomassi.com

Phone

+966 54 413 3653