Privacy Policy

KAVAK Complete Privacy Notice

DARIS INTERNATIONAL LLC DUBAI BRANCH, (“KAVAK”), a company duly incorporated and organized in accordance with the provisions of the laws of the United Arab Emirates, Commercial License Number 799709, domiciled at 48, 26th St - Al Quoz - Al Quoz Industrial Area 2 - Dubai, UAE, is responsible for the collection, use, storage, treatment, transfer and protection of the personal data of the owners (the "Owner", or the "Owners", as the case may be), under the terms of the Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data in Possession of Individuals (the "Law"), its Regulations (the "Regulations") and other applicable legal provisions (collectively, the "Data Protection Regulations").

For the purposes of this privacy notice (the "Privacy Notice"), "Personal Data" shall be understood as (i) any data relating to an identified person, or one who can be identified directly or indirectly by way of linking data, using identifiers such as name, voice, picture, identification number, online identifier, geographic location, or one or more special features that express the physical, psychological, economic, cultural or social identity of such person; it also includes Biometric Data as defined in the same Law (the "Personal Data"); and (ii) "Sensitive Personal Data" to that information that affects the most intimate sphere of the Data Subject, or whose improper use may give rise to discrimination or entail a serious risk for the Data Subject; in particular, those that may reveal aspects such as racial or ethnic origin, present and future state of health, genetic information, religious, philosophical and moral beliefs, , political opinions, sexual state, in accordance with the Law (the "Sensitive Personal Data").

KAVAK adheres to the guiding principles for the protection of Personal Data and Sensitive Personal Data:

1. Lawfulness: The processing of Personal Data carried out by KAVAK, will be carried out at all times in accordance with and in compliance with the provisions of the Data Protection Regulations.

2. Consent: The express consent, either in writing or through digital means, of the owner of the Personal Data and/or Sensitive Personal Data, will be required for the processing thereof.

3. Information: Through this Privacy Notice, KAVAK discloses to the general public, information regarding the existence and main characteristics of the treatment to which your Personal Data and/or Sensitive Personal Data will be subjected.

4. Quality: By virtue of this principle, KAVAK assumes that the Personal Data and/or Sensitive Personal Data that are processed in accordance with this Privacy Notice, are accurate, complete, relevant, correct and updated. It will be understood that such Personal Data and/or Sensitive Personal Data processed by KAVAK, comply with the above characteristics when provided by the owner thereof.

5. Purpose: Personal Data and Sensitive Personal Data collected by KAVAK may only be processed in accordance with the purposes mentioned in this Privacy Notice.

6. Loyalty: KAVAK undertakes to treat Personal Data and Sensitive Personal Data in a way that protects the interests and privacy of the owner.

7. Proportionality: KAVAK will only request from the owners those Personal Data and Sensitive Personal Data that are necessary, adequate and relevant in relation to KAVAK's purposes.

8. Responsibility: KAVAK is strictly responsible for the totality of the Personal Data and/or Sensitive Personal Data that the owners share with KAVAK.

KAVAK uses the strictest security measures to care for, access, use and handle its own information and data, as well as the information and data of KAVAK's employees, customers, suppliers and any other person, company or entity related to KAVAK. Likewise, we would like to remark that KAVAK uses the same security measures in relation to this Personal Data and/or Sensitive Personal Data as it does with its own.

This Privacy Notice is designed to make KAVAK's privacy practices understandable to individuals in a format that is easy to read, understand and navigate. KAVAK makes the Privacy Notice available to you for your knowledge, as well as your choices about how information is used:

Defined Terms

· Privacy Notice: Means, this Privacy Notice.

· Biometric Data: Personal Data resulting from processing, using a specific technique, relating to the physical, physiological, or behavioral characteristics of a Data Subject, which allows or confirms the unique identification of such the Data Subject..

· Economic and Financial Data: It is the information on the economic capacity, number and type of credit cards, issuing financial institution, mortgage credits, movable credits and credit history of the holders to which it refers, the resources owned and their capacity to face their debts in case of being authorized an installment sale plan with interest and reservation of title for the purchase of a used vehicle.

· Sensitive Personal Data: Means any data that directly or indirectly reveals a natural person's family, racial origin, political or philosophical opinions, religious beliefs, criminal records, biometric data, or any data related to the health of such person, such as his/her physical, psychological, mental, genetic or sexual condition, including information related to health care services provided thereto that reveals his/her health status

· Telematics Data: Means data obtained through GPS systems that may refer to location, speed, idle times, acceleration or hard braking, fuel consumption, vehicle faults and any other data derived from the use, operation and condition of the vehicle.

· ARCO Rights: Means the rights of access, rectification, cancellation and opposition.

· KAVAK: Means DARIS INTERNATIONAL LLC DUBAI BRANCH

· Law: Means the Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data

· Data Protection Regulations: Means, jointly, the Law, the Regulations, and other applicable legal provisions regarding Personal Data and Sensitive Personal Data.

· GPS or GPS Systems: Means Geographic Positioning System (Global Positioning System).

· Data Subject(s): Means the owner of the Personal Data or Sensitive Personal Data.

What will your Personal Data be used for?

The Personal Data collected by KAVAK from the Data Controllers will be used, among other things, for the following primary purposes: (i) the maintenance, development, control and implementation of the professional relationship, within the framework of the sale and purchase, lease, installment sale with interest, part-exchange and maintenance, with KAVAK; (ii) to comply with the applicable regulations regarding the prevention of money laundering; (iii) the performance of the work of billing, clarifications and collection follow-up; (iv) the performance of the work of personnel hiring, selection processes, payroll payments and other related tasks; (v) the determination of the investment and risk profile and transactional profile; (vi) to carry out credit bureau and credit history investigations with Credit Information Companies the company deems convenient; (vii) to provide information about certain products or services related to the object of the professional relationship referred to in point (i) above, and the changes derived therefrom; (viii) to keep the Holder's information duly updated; (ix) notifications on the change in conditions of the services provided, if applicable; (x) to collect, through the GPS of the KAVAK Vehicle, Telematics Data associated with the performance, use, operation and status of such KAVAK Vehicle; and (xi) to evaluate the quality of the service.

In addition, KAVAK will use your personal information for the following secondary purposes that are not necessary for the requested service, but that allow and facilitate the providing of better service, such as (i) sending information, advertising, communications and news; (ii) writing customer service reports as part of KAVAK's experience process; (iii) other marketing, advertising or commercial prospecting purposes; (iv) home service, (v) customer service; (vi) quality and customer satisfaction surveys; and (vii) market research.

In terms of the provisions of the Data Protection Regulations, when KAVAK does not inform the Data Subject of this Privacy Notice directly or personally but indirectly, the Data Subject shall have a period of 5 (five) business days from the date the Privacy Notice was made available to them so that they may, if applicable, express their opposition to the processing of their Personal Data or Sensitive Personal Data, since, in the event that such Holder does not express their opposition, it will be understood that they grant their consent regarding the content of this Privacy Notice to KAVAK.

Specifically, and with respect to each area of KAVAK, the purposes will be, by way of example but not limited to, the following, with the understanding that at all times, KAVAK will comply with the Data Protection Regulations:

I. Visitors

1. Control access.

2. Maintain security in our facilities through video surveillance.

II. Customers

1. Establish a business relationship.

2. To comply with and maintain the contractual obligations arising from the relationship with the Data Subject of the Personal Data and/or Sensitive Personal Data.

3. To establish security mechanisms for the protection of the people who visit KAVAK.

4. Evaluation of the products and services offered.

5. Advertising services.

6. For permission to use image, voice, photograph or video for testimonials, commercials and/or KAVAK capsules.

7.  Call recording through KAVAK's contact center for quality purposes.

8. Investigation of credit bureau information and credit history, through credit information companies or bank references, for those cases in which the customer has requested an installment sale plan with interest or the study for the granting of the same.

9. Investigation of criminal records.

10. Process payment transactions.

11. Protection against and the prevention of fraud and other legal or information security risks.

12. Payment follow-up.

13. Returns.

14. Statistical data.

15. Answer questions and respond to requests.

16. Access and services through electronic means.

17. Provide other services.

18. Elaboration of databases.

III. Suppliers

1. Establish a business relationship.

2. Establish security mechanisms for people visiting KAVAK.

3. To comply with and maintain the contractual obligations arising from commercial relations.

4. Perform internal audits, as well as audits by third parties contracted by KAVAK.

5. Make payments and carry out invoicing procedures.

6. Evaluation of services.

7. Advertising services.

8. Elaboration of databases.

IV. Newsletter, website and mobile application

1. Offering and evaluation of KAVAK products and services.

2. Sending information related to KAVAK.

3. If applicable, to establish a commercial and/or employment relationship between the Holder and KAVAK.

4. Consultations and surveys by KAVAK.

5. Knowledge and control of users visiting the website and downloading the KAVAK mobile application.

6. Storage of the traffic source.

7. User behavior monitoring.

8. Improve the browsing experience on the website and mobile application.

9. Information gathering.

10. Attend and follow up on questions, complaints and/or comments.

11. Use of cookies.

V. Selection and Recruitment

1. Analyze, select and qualify the most suitable candidates for the position offered within KAVAK.

2. Create a physical and/or digital file of the candidate.

3. Application of tests and evaluations.

4. To temporarily maintain a portfolio of potential candidates to fill a position within KAVAK.

5. Elaboration of databases.

6. Prepare and submit, if necessary, offer letters to candidates.

7. Conduct academic, employment and background investigations and request references.

8. Maintain communication with the candidate during the recruitment and selection process.

9. Incorporate potential candidates through the referral program.

VI. Administrative and Unionized Staff

1. Establish an employment and/or contractual relationship with persons providing services to KAVAK.

2. To give continuity and fulfillment to the work and/or contractual relationship with the people who provide their services to KAVAK.

3. To establish security mechanisms within KAVAK facilities.

4. To comply with the administrative and legal requirements made by the competent authorities and prior written orders, which are related to work and/or contractual relations.

5. Elaboration of databases.

6. Safeguarding of personal documentation for the generation of internal files.

7. Authorize and deliver the necessary accesses to KAVAK's facilities.

8. Provide working tools necessary to perform their work.

9. To arrange major medical and life insurance, if applicable.

10. Training, coaching and performance evaluations.

11. Payment and administration of payroll, benefits, salaries, wages, benefits, bonuses, reimbursements, pensions and other benefits.

12. Recording of video calls.

13. For authorization to use image, voice, photography or video for internal or external use in printed materials, digital, social networks, among others for internal material, advertising, training, testimonials, commercials and/or KAVAK capsules.

14. To carry out statistics, analyses or reviews in order to ensure the confidentiality of KAVAK's proprietary information (such as trademarks, trade secrets and confidential information) and to measure work effectiveness; for these purposes, KAVAK may carry out random reviews of information contained in computers and other devices provided as work tools.

15. Conduct investigations in case of complaints, violations of applicable laws or KAVAK's internal policies.

16. To integrate physical and/or digital files of employees.

VII. GPS and in-vehicle monitoring systems

1. Telematics Data Collection.

2. Statistical data generation.

3. Evaluation of the products and services offered.

4. To comply with and maintain the contractual obligations arising from the relationship with the Holder of the Personal Data and/or Sensitive Personal Data.

5. Study of driving behavior.

6. Diagnosis of vehicle problems.

7. Elaboration of databases.

8. Real-time geolocation of the KAVAK vehicle for monitoring, emergency solutions and safety.

9. Engine immobilization in case of theft.

KAVAK will periodically update the Personal Data and/or Sensitive Personal Data of the Data Controllers, requesting from the Data Controllers, as required from time to time, the necessary information to carry out such updates and, if applicable, authorizations.

What Personal Data and/or Sensitive Personal Data is required to achieve the above?

For the above purposes, KAVAK requires or may require the collection of the following Personal Data and/or Sensitive Personal Data from the Data Controllers, as the case may be and depending on the type of operation to be performed. For those Sensitive Personal Data that KAVAK collects and processes, the express consent of the Data Owner will be required at all times. The Personal Data and Sensitive Personal Data collected and processed by KAVAK may belong to the categories of (i) identification data, (ii) employment data, (iii) education data, (iv) banking and billing data, (v) vehicle identity data and (vi) Telematics Data.

I. Customers

Individuals:

Identifiers:

Name, address, Emirates ID number, home phone number, cell phone number, signature, place and date of birth, nationality, age, proof of address, biometrics consisting of fingerprints, voice, hand geometry and facial features.

Vehicle identity data:

· Unit invoice, vehicle registration card, invoice or rebill endorsements, current, installment sale contracts with interest with reservation of title of the vehicles, telematics data consisting of vehicle performance, usage, operation and condition, speed information, continuous readings, odometer, battery usage management information, electrical system functions, information system data, safety-related data, trip data and distances traveled, repair history and vehicle service history and driving patterns.

Electronic:

E-mail, social networks, geolocation, IP address and digital signature and/or advanced electronic signature.

Legal:

Criminal records, contracts or purchase orders, official identification.

Economic and Financial:

Bank account numbers, amount of the transaction or contract, amount of the requested monthly payment plan, credit history, quotes, quotations, past and present credit history (which is obtained through the information provided by the Credit Information Society(s)).

Legal entities.

Identifiers:

Name or corporate name, address, proof of address, articles of incorporation, telephone number.

Vehicle identity data:

. Unit invoice, vehicle registration card, invoice or rebill endorsements, current, installment sale contracts with interest with reservation of title of the vehicles, telematics data consisting of vehicle performance, usage, operation and condition, speed information, continuous readings, odometer, battery usage management information, electrical system functions, information system data, safety-related data, trip data and distances traveled, repair history and vehicle service history and driving patterns.

Electronics:

E-mail, social networks, website.

Legal:

Criminal records, contracts or purchase orders.

Economic and Financial:

Bank account numbers, account statement, Bank where the account is held, amount of the transaction or contract, amount of the requested monthly payment plan, credit history, quotations.

Credit Information Companies:

In the case of requesting an instalment with interest with reservation of title sales plan, your credit history or any other information deemed necessary will be reviewed.

3. Main contact and/or legal representative of a legal entity.

Identifiers:

Name; address, telephone and extension(s), cell phone number, signature, place and date of birth, nationality, age, biometrics consisting of fingerprints, hand geometry and facial features.

Electronics:

Business e-mail, electronic signature and/or advanced electronic signature.

Professional:

Occupation.

Legal:

Criminal record, power of attorney, contracts or purchase orders and official identification.

II. Suppliers

Individuals:

Identifiers:

Name; address, home phone number, cell phone number, signature, place and date of birth, nationality, age, proof of address, biometrics consisting of fingerprints, hand geometry and facial features.

These data are collected only if you are an individual with business activity, and your tax and contact details are the same as your personal data.

Electronics:

E-mail, social networks, website, digital signature and/or advanced electronic signature.

Legal:

Criminal record, contracts or purchase orders and official identification.

Economic and Financial:

Bank account numbers, Bank where the account is held, amount of the transaction or contract, personal or commercial references.

Legal entities.

Identifiers:

Name or corporate name, address, proof of address, articles of incorporation, telephone number.

Electronics:

E-mail, social networks, website, electronic signature and/or advanced electronic signature.

Legal:

Criminal record, contracts or purchase orders.

Economic and Financial:

Bank account numbers, account statement, bank where the bank account is held, amount of the transaction or contract, amount of the requested monthly payment plan, credit history, quotations.

Credit Information Companies:

In the case of requesting an installment with interest with reservation of title sales plan, your credit history or any other information deemed necessary will be reviewed.

3. Main contact and/or legal representative of a legal entity.

Identifiers:

Name, address, telephone and extension, cell phone number, signature; place and date of birth, nationality, age, biometrics consisting of fingerprints, iris, hand geometry and facial features.

Vehicle identity data, such as invoice, registration card, vehicle transfer notification, proof of current address, installment with interest with reservation of title of the vehicle sales contract.

Electronics:

Business e-mail, digital signature or advanced electronic signature.

Professional:

Occupation.

Legal:

Criminal record, power of attorney, contracts or purchase orders and official identification.

III. Newsletter, website and mobile application.

Individuals:

Identifiers:

Name, home phone number, cell phone number.

Academic:

University attended, degree, curriculum vitae.

Electronics:

E-mail, social networks, IP address.

Economic and Financial:

Cardholder's name, expiration date, security code CSC.

These data are collected only if the individual chooses to enter them.

IV. Selection and Recruitment

Identifiers:

Name, address, home phone number, cell phone number, signature, date of birth, age, photograph, nationality and/or immigration documents, personal references, audio and video while on KAVAK premises.

Electronics:

E-mail, social networks, digital signature.

Legal:

Official Identification.

Academic:

Level of studies, professional credentials, academic records and/or records of grades, degrees, certificates, diplomas, official certificates, letters of recommendation, and/or recommendations.

Professional:

Resume or curriculum vitae, employment application, employment references, psychometric evaluations, knowledge and technical evaluations, information obtained during the interview process.

V. Administrative Staff

Identifiers:

Name, birth certificate, age, names of parents and beneficiaries, marriage certificate or marriage registration data, birth certificate of child(ren), address, telephone, cell phone number, signature, (in case of compulsory or optional military service), photograph, nationality and/or immigration documents, personal references, audio and video.

Electronics:

E-mail, IP address, social networks.

Academic:

Level of studies, professional credentials, academic records and records of grades, degrees, certificates, diplomas, official certificates, letters of recommendation, and/or recommendations.

Professional:

Employment application, contracts, union membership, resume or curriculum vitae, employment incident reports, training, extracurricular activities, employment references, social security number, employer contributions, retirement savings account number, attendance list, biometric attendance record, employee number.

Legal:

Criminal record and personal identification.

Economic and Financial:

Salary, withholdings, bank account number and/or interbank code, life, and major medical insurance.

Legal:

Contracts, powers of attorney, lawsuits, sentences or arbitral resolutions.

Health and biometrics:

Clinical record, references or description of symptoms, diseases, medical incapacity, disability, surgical intervention, vaccinations, medication consumption, use of devices, psychometric evaluation, hand geometry, fingerprint, facial features and body temperature.

VI. GPS, Monitoring and/or Geolocation Systems

Through GPS, KAVAK may collect, store or process certain information from your vehicle, which will vary from model, year, and version of the vehicle.

Telematics Data associated with the performance, usage, operation and condition of your vehicle may be collected for the services KAVAK provides, as well as vehicle enhancement purposes.

KAVAK will be able to dynamically connect to your vehicle to diagnose and resolve problems with your vehicle. This dynamic connection also allows KAVAK to view the current location (geolocation) of your vehicle, but such access is restricted to a limited number of employees or third parties with whom KAVAK has joint projects under strict confidentiality.

With whom will the Personal Data be shared?

KAVAK informs you that the Personal Data of the Data Controllers may be transferred or forwarded by KAVAK within and outside the country with the following persons, companies, organizations or authorities other than KAVAK, for the following purposes and in the following cases:

1. A referral of Personal Data will be made with other companies that make up the KAVAK group when it is deemed necessary to subcontract all or part of the same or any other third party authorized and contracted for the provision of such services. Exclusively for those purposes provided in the Data Protection Regulations and under the strictest clauses of confidentiality and security of information implemented and required by KAVAK.

2. A referral of Personal Data will be made with Financial Institutions, Banks and/or Credit Information Companies with which KAVAK has partnered or deems necessary to partner with, to create and offer a product or service jointly, for the processing of payment transactions, returns and to be able to access credit history and credit bureau information in case of requiring an installment sale plan with interest with reservation of title for the purchase of a used vehicle.

3. A referral of Personal Data will be made with those companies that provide KAVAK or its affiliates and/or subsidiaries, support services for management and technical support, to the extent that such access is essential for the execution by KAVAK of the services it provides, under the strictest confidentiality and information security clauses implemented and required by KAVAK.

4. A referral of Personal Data will be made when the Holder requests an installment sale with interest and reservation of title to acquire a used vehicle through our Web Page or Mobile Application through our authorized supplier by instructions of KAVAK for the review of the credit bureau information or credit history of the Holder. For the purposes of the foregoing, in the event that the Holder voluntarily provides his/her Personal and Financial Data through KAVAK's Website or mobile Application or KIKOYA's, as the case may be, such action shall be considered as his/her absolute consent and his/her absolute and express acceptance of the Privacy Notice and consent to the transfer of data between both companies in accordance with the provisions of Article 14 of the Law; so it will be understood as his/her express consent to comply with the primary purposes established for its due treatment and that in its case may be authorized the installment sale with interest required.

5. A referral of Personal Data will be made when you apply for a vacancy through our Website or Mobile Application of the Personal Data and/or Sensitive Personal Data contained in your job application, which will be collected by KAVAK and will be shared with our authorized vendor which has been contracted by KAVAK to help manage your recruitment and hiring and you are informed that the cloud it uses is located in the United States of America.  Consequently, we inform you that as to the use of the cloud, your Personal Data and/or Sensitive Personal Data will be transferred to the United States of America once you voluntarily submit it through this site; however, at all times it will be restricted and processed only for the purposes set forth in this Privacy Notice.

6. A transfer of Personal Data will be made with each and every third party with whom KAVAK enters into a transaction of a commercial nature, either purchase, sale, part-exchange and/or installment sale with interest and reservation of title, which are necessary for the completion and transfer of ownership or ownership of any of the vehicles of KAVAK, which will be authorized in a reliable manner through the formalization of the relevant contracts.

The processing of Personal Data carried out with any third party shall comply with the Data Protection Regulations, in the understanding that such third party shall have sufficient security systems to guarantee the protection of such data.

KAVAK undertakes not to transfer your personal information to third parties without your consent, except for the exceptions provided for in Articles 22 and 23 of the Law.

If the Data Subject does not express his/her opposition to the transfer of his/her Personal Data at the time of it being requested by KAVAK, it will be understood that he/she has given his/her consent to do so.

May KAVAK disclose Personal Data to third parties?

In accordance with Data Regulations, KAVAK may transfer or forward your Personal Data to national or international third parties in accordance with the primary purposes set forth in this Privacy Notice and, if applicable, the exceptions provided in Articles 22 and 23 of the Law.

In the event of a transfer of Personal Data, KAVAK will provide you with a copy of the Privacy Notice and the purposes of such transfer with the understanding that the recipient of such Personal Data will assume those obligations arising from the processing of the Personal Data and/or Sensitive Personal Data in question, under the terms of Article 22 and 23 of the Law.

In order to duly perfect the purchase, sale, installment sale with interest and reservation of title and/or lease transactions and for the purpose of having a proper integration of the customer's file, KAVAK may share your Personal Data with those third parties and/or new customers who intend to enter into any of the above transactions with KAVAK, for the sole purpose of demonstrating the historical tract of ownership of the KAVAK vehicle in question.
KAVAK wants to remark that the transfers that may be made to the syndicate and to external firms and/or consulting firms, are covered by Article 14 of the Law, so that the data subject cannot oppose KAVAK to make such remissions at any time.

In all cases, your Personal Data may be shared with affiliated and subsidiary companies that are part of KAVAK, which will safeguard the data in the terms established in the Data Protection Regulations.

How can the Data Subject control his/her Personal Data and/or Sensitive Personal Data once it has been provided?

The Data Subject may exercise at any time, under the terms and conditions set forth in the Law, the rights of access, rectification, cancellation and opposition (ARCO Rights) to the processing of the same; to achieve the above, he/she must:

1. Submit your application physically at the address indicated at the beginning of this notice or by e-mail: arco@kavak.com.

2. The request (physical or electronic) for ARCO Rights must state:

a. Name of the Data Subject of the Personal Data and/or Sensitive Personal Data, or if applicable, the name of the minor and the name of the guardian or legal representative of the minor.

b. The address or electronic means to communicate the response to your request.

c. The right you are exercising, that is, if it is the right of access, rectification, cancellation and/or opposition.

d. The clear and precise description of the Personal Data and/or Sensitive Personal Data with respect to which it seeks to exercise any of the rights set forth in the preceding paragraph.

e.In the case of the right of rectification, you must indicate, at least, the Personal Data and/or Sensitive Personal Data that are incorrect, or that you wish to update.

f. In the case of the right of cancellation or opposition, it shall indicate, at least, the Personal Data and/or Sensitive Personal Data on which such rights are being exercised, and any data or information for which the Data Subject considers that such rights should be exercised.

g. It should also point out any element or document that facilitates the location of the Personal Data and/or Sensitive Personal Data.

When exercising one of the ARCO Rights, you must prove that you are the Owner of the information you require or, if applicable, the legal representative accompanied by supporting official document (power of attorney, delegation of powers, etc.), which must be attached to the request and presented, if applicable, at the time you receive the response to your request.

The deadline for KAVAK to respond to your request is 20 (twenty) days from receipt, and in the event that the response is favorable to your interests, it will be delivered within 15 (fifteen) days; it is not omitted to note that these deadlines may be extended. The response to your request will be made by the same means by which the request was made.

It is important for the Data Subject to take into account that not in all cases will it be possible to respond to his/her request immediately since it is possible that due to some legal obligation, his/her Personal Data and/or Sensitive Personal Data must continue to be processed.

Likewise, the Data Subject must consider that for certain purposes, the revocation of his/her consent will imply that the service he/she requested can no longer be provided, or the termination of his/her relationship with KAVAK.

The Personal Data and/or Sensitive Personal Data that are delivered to KAVAK will be safeguarded, preserved and protected in accordance with the provisions of the applicable legislation and its internal policies in order to maintain the confidentiality of such Personal Data and/or Sensitive Personal Data. KAVAK has sufficient security measures for the protection, confidentiality and assurance in order to restrict access to Personal Data and/or Sensitive Personal Data to unauthorized persons, as well as the processing of Personal Data and/or Sensitive Personal Data in contravention of the provisions of this Privacy Notice. KAVAK, its employees, representatives, subcontractors, consultants, subsidiaries, affiliates and/or related companies, third-party service providers duly contracted or with whom KAVAK has a business relationship and/or third parties involved in any phase of the processing of Personal Data and/or Sensitive Personal Data of the Data Subject, shall keep confidentiality regarding these, an obligation that will subsist even after the end of the relationship between such persons and KAVAK.

Address your ARCO Rights requests to:

Name of the department of Personal Data and/or Sensitive Personal Data: Department of Administration and Finance.

Address: 48, 26th St - Al Quoz - Al Quoz Industrial Area 2 - Dubai, UAE

E-mail:

Telephone number: +971 4 339 0380

How long will the Personal Data and/or Sensitive Personal Data be kept?

KAVAK will delete, without notice, the data and information of the Data Controllers when they are no longer necessary for the fulfillment of the needs referred to in this Privacy Notice.

Those Personal Data of the Registrants who have decided not to purchase a service from KAVAK will be deleted 72 (seventy-two) months after any registration they have made.

KAVAK will not be able to delete Personal Data and/or Sensitive Personal Data when there is a contractual or legal impediment or when there is a resolution issued by a competent authority that restricts the deletion of such data.

How KAVAK may collect your Personal Data and/or Sensitive Personal Data and what is the purpose?

KAVAK may collect information from you or your devices in the following ways:

Newsletter, website, app: KAVAK may collect your information through its websites, software applications, social media pages, email, among other digital means.

Application for Installment Sales with interest and other forms: KAVAK may collect additional information from you or third parties on your behalf on applications for installment payments and other KAVAK product forms; such information may include your date of birth, banking information, credit information and vehicle information. KAVAK also receives your information from consumer reporting agencies, such as your creditworthiness and credit history.

Information may be collected from other sources, such as public databases, companies with which KAVAK works together, third party vehicle repair or automotive service centers, as well as social media platforms.

KAVAK centers: KAVAK may collect your information when you are not connected to any network, i.e., when you visit KAVAK centers, branches, hubs, workshops, as well as data from your vehicle at such sites.

Device: Your device and most browsers collect certain information automatically, such as your Media Access Control ("MAC") address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the digital services the Cardholder is using. KAVAK uses this information to verify that the digital services are working properly.

KAVAK will also collect information in a form that, by itself, does not permit direct association with any specific individual. KAVAK may collect, use, transfer and disclose, for any purpose, data that does not personally identify an individual. If non-personally identifiable data is combined with an individual's personal information, the combined information will be treated as personal information for as long as it remains combined.

How does KAVAK protect your Personal Data and/or Sensitive Personal Data?

KAVAK is committed to protect your Personal Data and/or Sensitive Personal Data and to implement appropriate administrative, technical, and physical security measures to protect against any unauthorized or unlawful processing and against any accidental loss, destruction, or damage. These measures include policies, procedures, employee training, physical access control and technical elements related to information access controls.

In the event of a security breach at any stage of the processing of your Personal Data and/or Sensitive Personal Data, which significantly affects your economic or moral rights, KAVAK will immediately notify you by email or if it cannot contact you by email, then it will use its website or mobile application so that the Data Subject can take the necessary measures corresponding to the defense of his or her rights.

Cookies and Web beacons

KAVAK uses various technologies that improve the efficiency of its websites, including the user experience when browsing KAVAK sites, so we consider it necessary to make you aware of the definition of these tools:

Cookies: These are small blocks of information that are used to collect and store information from the websites you visit, to later send it to your browser. You are reminded that, as the Holder, you can disable or adjust the use of cookies by following the procedures of the internet browser you use through the following links:

· Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete-manage-cookies

· Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies

· Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647

· Safari: http://support.apple.com/kb/PH5042 

· Opera: http://www.opera.com/browser/tutorials/security/privacy/

· Adobe (flash cookies): http://www.adobe.com/privacy/policies/flash-player.html

In case you disable cookies, you may experience some anomalies or failures when using KAVAK digital services.

Web Beacons: May refer to a visible or hidden image embedded within our website or email.

Privacy Notice Update

KAVAK reserves the right to make changes or updates to this Privacy Notice at any time to comply with legislative or jurisprudential reforms, internal policies or new requirements, being that the updated and applicable version will at all times be published through the Web Page www.kavak.com.

KAVAK undertakes to keep the Holder informed of any changes that this Privacy Notice may undergo through the Website www.kavak.com and its mobile application, integrating any modification or update during a maximum period of 10 (ten) working days after the change is made.

Any modification to this Privacy Notice may be notified to the email address you have registered on the website and/or mobile applications of KAVAK or through any other means, whether oral, printed or electronic that KAVAK considers suitable for this purpose. In addition, you may request at any time the Privacy Notice by writing to the following email: arco@kavak.com

If you do not express your opposition or refusal to the provisions of this Privacy Notice, it is understood that by using KAVAK's website and mobile application, you consent to the terms and/or primary and secondary purposes of the processing of your Personal Data and/or Sensitive Personal Data in accordance with this Privacy Notice.