Privacy Policy

In this Privacy Policy, ‘us’, ‘we’ or ‘our’ means Xanadu Technology Limited (Licence Number: CL11172), herein Xanadu. We are committed to respecting your privacy. Our Privacy Policy outlines how we collect, use, store, and disclose your personal information.

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We reserve the right to modify our Privacy Policy from time to time by publishing updates on our website. Please visit our website periodically to stay informed about our current Privacy Policy.

Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, such as your credit card details.

 

What personal information do we collect?

We may collect the following types of personal information:

    • Name;
    • Company name;
    • Mailing or street address;
    • Email address;
    • Telephone number and other contact details;
    • Age or date of birth;
    • Credit card information;
    • Your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
    • Details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
    • Any additional information relating to you that you provide to us directly through our website or app, or indirectly through your use of our website or app, or online presence or through other websites or accounts from which you permit us to collect information;
    • Information you provide to us through customer surveys, or any other personal information that may be required to facilitate your dealings with us. We may collect these types of personal information either directly from you (through the use of any of our standard forms, over the internet, via email, through a telephone conversation with you, or as otherwise set out in the paragraph below), or where it is unreasonable or impractical to collect information directly from you, from third parties. For example, if we provide services in connection with Canva, we may collect your personal information from Canva as necessary to deliver those services.
     

    We may collect this information when you:

      • Register on our website or app;
      • Communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
      • Interact with our sites, services, content and advertising; or
      • Invest in our business or enquire about a potential purchase in our business 

      In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices related to the records of our current and former employees, which are exempt from the Dubai International Financial Centre Data Protection Law (DIFC Law No. 5 of 2020) and any other applicable data protection laws.
      ‍

      Why do we collect, use and disclose personal information?

      We collect and process your personal information on one or more of the following lawful bases:

        • your consent;
        • performance of a contract with you;
        • compliance with legal obligations;
        • protection of legitimate interests pursued by us or by a third party, provided your rights and freedoms do not override those interests; or
        • where the processing is necessary to protect your vital interests.

        We may collect, hold, use and disclose your personal information for the following purposes:

          • Providing services to you or someone you know;
          • To enable you to access and use our website & services;
          • To operate, protect, improve and optimise our website, services, business, and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
          • To send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
          • To send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
          • To administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
          • To comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
          • To consider your employment application. 

          We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information to enable them and us to develop anonymised consumer insights. This allows us to better understand your preferences and interests, personalise your experience, and enhance the products and services you receive.

           

          Data Retention

          We retain personal information for as long as necessary to fulfil the purposes for which it was collected and to comply with our legal obligations. We securely delete or anonymise information when it is no longer required.

          Failure to provide information

          If the personal information you provide to us is incomplete or inaccurate, we may be unable to offer you, or someone else you know, the services you, or they, are seeking.

          Do we use your personal information for direct marketing?

          We and/or our carefully selected business partners may send you direct marketing communications and information about our products and services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with applicable DIFC and United Arab Emirates laws relating to electronic communication and the Dubai International Financial Centre Data Protection Law (DIFC Law No. 5 of 2020) and any other applicable data protection laws. We have obtained your implied consent for the activities arising from our ongoing business relationship. You may opt out of receiving marketing materials from us by contacting us using the details set out below under “Contact Us” or by using the opt-out facilities provided (eg an unsubscribe link).

           

          To whom do we disclose your personal information?

          We may disclose personal information for the purposes described in this privacy policy to:

            • Our employees and related bodies corporate;
            • Third-party suppliers and service providers such as Canva (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
            • Professional advisers, dealers and agents;
            • Payment systems operators (eg merchants receiving card payments);
            • Our existing or potential agents, business partners or partners;
            • Our sponsors or promoters of any competition that we conduct via our services;
            • anyone to whom our assets or businesses (or any part of them) are transferred;
            • Specific third parties authorised by you to receive information held by us; and/or;
            • Other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law. 

            Disclosure of personal information outside DIFC and the United Arab Emirates

            We may transfer personal information outside of the Dubai International Financial Centre (DIFC) and the United Arab Emirates, including to jurisdictions that may not have the same data protection standards as those in the DIFC. In such cases, we will take reasonable steps to ensure that appropriate safeguards are in place to protect your personal information, consistent with the requirements of the DIFC Data Protection Law

             

            Using our website and cookies

            We may collect personal information about you when you use and access our website.

            While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the Internet Protocol address assigned to your computer.

            We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser, but our websites may not work as intended for you if you do so.

            We may also use cookies to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Dubai International Financial Centre Data Protection Law (DIFC Law No. 5 of 2020) and any other applicable data protection laws. We will handle any personal information collected by cookies in the same manner as we handle all other personal information, as described in this Privacy Policy.

             

            Security

            We may hold your personal information in either electronic or hard copy form.

            We take reasonable steps to protect your personal information from misuse, interference, and loss, as well as unauthorised access, modification, or disclosure. We use a combination of physical, administrative, personnel, and technical measures to protect your personal information. For example, we adhere to industry-standard best practices related to information security. However, we cannot guarantee the security of your personal information.

             

            Links

            Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies of other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

             

            Accessing or correcting your personal information

            You can access the personal information we hold about you by contacting us using this form. Sometimes, we may not be able to provide you with access to all of your personal information, and in such cases, we will inform you of the reason. We may also need to verify your identity when you request your personal information.

            If you believe that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure it is corrected.

             

            Your rights under the DIFC Data Protection Law

            Under the DIFC Data Protection Law, you have the right to:

              • access the personal information we hold about you;
              • request correction of inaccurate or incomplete data;
              • request erasure (‘right to be forgotten’);
              • object to or restrict processing;
              • data portability (transfer of your information to another controller); and
              • withdraw consent at any time (without affecting the lawfulness of processing before withdrawal). 

              To exercise any of these rights, please get in touch with us using the details below.

               

              Making a complaint

              If you believe we have breached the DIFC Data Protection Law, you can contact us directly using this form. If you are not satisfied with our response, you have the right to complain to the DIFC Commissioner of Data Protection at commissioner@dp.difc.ae

               

              Contact Us

              For further information about our Privacy Policy or practices, or to access or correct your personal information, or to make a complaint, please contact us using this form.