PWR HUB DMCC'S PRIVACY POLICY

We understand that the security and confidentiality of the data of our members, subscribers, visitors, and customers are very important. That's why we take data protection seriously and are committed to protecting your personal data throughout your use of the website www.enroush.com ("the Website") and our services.

1. General Information
This Privacy Policy ("Policy") explains how the company PWR HUB DMCC, a legal entity organized and operating in accordance with the United Arab Emirates law, with its registered office at Unit No: 3O-01-BA1123
Jewellery & Gemplex 3, Plot No: DMCC-PH2-J&GPlexS, Dubai, United Arab Emirates, registered under the number DMCC189449, legally represented by Carmen Lumina, acting as the administrator, hereinafter referred to as the "Company," in accordance with the provisions of Regulation (EU) 679/2016 of the European Parliament and of the Council of 27 April 2016, collects, processes, and protects your personal data.

Personal data refers to information that is directly or indirectly related to you as an individual or a legal entity ("Personal Data" or "Data").

The Company recognizes the importance of your data and is committed to protecting their confidentiality and security by processing your personal data in full compliance with Regulation (EU) 679/2016 ("GDPR") and Law 190/2018 regarding the implementation of Regulation (EU) 679/2016.

We reserve the right to periodically update and modify this Policy to reflect any changes in how we process your Personal Data or any changes in legal requirements. In the event of any such changes, we will display the modified version of the Policy on our Website, so please check its contents periodically.

Regarding the Personal Data we collect, the Company is the "data controller," meaning the entity that determines the purposes and means by which personal data are processed.

Considering the need to comply with the provisions of the GDPR and our dedication to taking care of your Personal Data (which may include names, surnames, representatives, phone numbers, ID numbers, tax identification numbers, bank account information, email addresses, etc., depending on the purpose of processing), which are stored in our database, please be informed that they are used solely for the successful fulfillment of processes carried out in relation to you (including but not limited to: sales/contract execution, orders, shipping and deliveries, warranties) and maintaining customer relationships - customer support service, recruitment processes, newsletters, etc.

If you wish to contact us regarding your Personal Data or this Policy, please use the following contact information:

PWR HUB DMCC
Address: Unit No: 3O-01-BA1123
Jewellery & Gemplex 3, Plot No: DMCC-PH2-J&GPlexS, Dubai, United Arab Emirates
Email: privacy@enroush.com

We would also like to inform you that our Online Store is hosted by Shopify.com, hereinafter referred to as "Shopify." Shopify Inc. is a Canadian e-commerce company with its headquarters in Ottawa, Ontario, K2P 1L4, at 150 Elgin Street, 8th floor. This is also the name of its e-commerce platform for online stores. Shopify provides us with the online e-commerce platform that allows us to sell our products and services to you. Your data may be stored through Shopify's data storage, databases, and the general Shopify application.

2. Principles related to the processing of Personal Data
'Lawfulness, fairness, and transparency': Personal Data is processed in a legal, fair, and transparent manner towards the data subject;

'Purpose limitation': Personal Data is collected for specific, explicit, and legitimate purposes and is not further processed in a manner that is incompatible with these purposes;

'Minimization of data': Personal Data is adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;

'Accuracy': Personal Data is accurate and, where necessary, kept up to date. Personal Data that is inaccurate, considering the purposes for which they are processed, is erased or rectified without delay;

'Storage limitation': Personal Data is kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the Personal Data is processed;

'Integrity and confidentiality': Personal Data is processed in a manner that ensures appropriate security of the data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, by taking appropriate technical or organizational measures;

'Responsibility': The Company applies effective procedures and policies to comply with the current European and national data protection legislation.

3. Purposes and grounds for the collection and processing of your Personal Data
The Company collects and processes your Personal Data for the following purposes:
- To carry out the contractual relationship between you and the Company, including order processing, validation, shipping, and invoicing of orders placed by you, informing you about the order status, organizing the return of ordered products, etc. The processing of your Data for this purpose is based on the contract concluded between you and the Company. Providing your Personal Data is necessary for the execution of this contract. Refusal to provide data may result in the impossibility of conducting contractual relations.

Legal basis: Art. 6 (1) (b) GDPR - processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract.

- For marketing purposes, to inform you about our promotional campaigns, to communicate news and updates about our services and products, and to verify your satisfaction with the Company's activities. In this case, the legal basis is your consent.
Legal basis: Art. 6 (1) (a) GDPR - the data subject has given consent to the processing of their personal data for one or more specific purposes.

- To fulfill the legal obligations incumbent upon the Company in the context of the services provided, including tax obligations, as well as archiving obligations; to comply with applicable laws, regulations, codes of conduct, or guidelines applicable to the Company or for the purpose of law enforcement and cooperation with competent authorities (including, but not limited to, tax and judicial authorities). In connection with any claim, action, or procedure and/or for the protection or exercise of the Company's rights and obligations, both contractual and legal. The processing of your Data for these purposes is necessary based on legal and contractual obligations.
Legal basis: Art. 6 (1) (c) GDPR - processing is necessary for compliance with a legal obligation to which the company is subject.

- At the same time, we use your Personal Data to improve the services and products offered, as well as your experience. We collect your Personal Data to analyze your interests, trends, and consumption patterns. By better understanding social media users, we can tailor our websites to users' identified preferences and improve the Company's products and services in general.
The legal basis for this processing is your consent.
Legal basis: Art. 6 (1) (a) GDPR - the data subject has given consent to the processing of their personal data for one or more specific purposes.

- To respond to your requests, questions, and comments and to fulfill them. The legal basis for processing is our legitimate interest in responding to your requests. Legal basis: Art. 6 (1) (f) GDPR - processing is necessary for the purposes of the legitimate interests pursued by the company.

- Storing and distributing the content you post on social media. You can share content on social media, such as photos of yourself, text, hashtags, videos, and recordings. When you communicate such content on social media, we may decide to distribute some of it on our websites in the context of advertising campaigns and, in general, to present and highlight our products and services.
To facilitate your communication with other members, for example, by using the messaging center. The legal basis for processing is your consent.
Legal basis: Art. 6 (1) (a) GDPR - the data subject has given consent to the processing of their personal data for one or more specific purposes.

If we intend to process your Personal Data for a purpose other than those mentioned above, we will provide you, before such further processing, with information regarding the respective secondary purpose, as well as any relevant information.

4. Types of Personal Data Collected:
The Personal Data collected by the Company include: name, surname, company name, the name of the legal representative, VAT number, trade registry registration number, CNP (Personal Identification Number), gender, date of birth, email address, delivery address, billing details, payment method, phone number, bank card data, photos, public social media profile (name, profile URL, photos, 'likes,' location, other public information on the profile), user-generated content on social media (photos, texts, videos, symbols, hashtags, posts you share on social media), location information, hobbies and interests, consumption habits, browser and device information (IP address, MAC address, Google Ad ID, advertiser ID), server log file information, application usage data, Personal Data related to activity/engagement (e.g., date and time of activity on Company websites, number of visits, accessed elements), as well as any other similar data.

During the registration process, order placement, or simply by using the Enroush Site, you may choose to provide any of the listed Personal Data, including certain 'Sensitive Information.' Sensitive Information refers to Personal Data related to sensitive aspects, such as racial or ethnic origin, political opinions, religion or other beliefs, health or medical condition, criminal record, membership in trade unions, sexual orientation.

However, we ask that you do not send or disclose any Sensitive Information on or through the Company's Site or media page or in any other way to us.

We may collect information about your activities or posts on the Enroush Site when you choose to interact with the Company through emails or letters, or when other Enroush Site users or third parties send us correspondence, which may include their comments about you. All this information will be kept in a file accessed only by the Company's authorized personnel or representatives.

In some cases, you may choose to use our referral services to tell a friend or friends about us. In this case, we will ask for your friend's name and email address and send an invitation to their address to visit the Enroush Site. We will use your friend's name and email address only to send an invitation and to track the status of the referral. Your friends can use the unsubscribe function in the email or contact us at privacy@enroush.com to request the removal of their email address from our records.

If you, as a user of the Enroush Site or a person who interacts with the Company in any way, refuse to provide your agreement regarding the provision of your Personal Data, you may not be able to access some or all of our services.

5. How We Collect:
- Personally, through direct contact with you - for example: by contacting you through our customer service;
- By providing services or products to you - when you use our services or products, such as when placing an order, you need to provide us with your Personal Data so we can process your order, reservation, etc.;
- Through registration - in the context of creating a user account, when placing an order through our Site or in any other way resulting from the use of the www.enroush.com Site;
- Through affiliated social media pages such as Instagram, Facebook, etc.;
- By subscribing to the newsletter;
When providing your Personal Data to the Company through the creation of a user account, you will be able to review, modify, and delete many of these pieces of information at any time, including: email address, home address (city, postal code, country), password, profile data, etc.

6. Duration of Data Processing
The Company will process your Personal Data for as long as necessary to achieve the processing purposes mentioned above.

In certain circumstances, we may retain your Personal Data for longer periods, for example, when we are required to do so in accordance with legal, regulatory, tax, or accounting requirements. The Company will keep your Personal Data for the period of time necessary to comply with the specific legal obligations related to our business field or the applicable statutory retention periods or for compliance with archiving obligations imposed by applicable law (e.g., those specific to the financial and accounting domain).

In certain circumstances, we may retain your Personal Data for extended periods to maintain an accurate record of your relationship with us in case of any complaints or issues that may arise, or if we reasonably believe there is a prospect of a dispute related to your Personal Data or transactions.

If you are a customer of the Company, we will process your Personal Data for the entire duration of the contractual relationships and thereafter in accordance with the legal obligations incumbent upon the Company (e.g., for financial and accounting supporting documents for which the legal retention period is 10 years from the date of the closure of the financial year in which they were prepared).

If you choose to delete your user account and you are a customer, we will no longer send you emails and/or SMS of this kind. However, please note that deleting the account will not automatically result in the deletion of your Personal Data.

If you wish to stop the processing of your Personal Data or request data deletion, you can exercise your rights as detailed in point 9 below. If you request an account deletion, but there is at least one active order on that account, the account deletion request will only be recorded after the products have been delivered and the last active order has been completed.

If you withdraw your consent for data processing for marketing purposes, the Company will cease processing your Personal Data for this purpose, without affecting the processing carried out by the Company based on your consent before its withdrawal.

7. Disclosure of Personal Data
In order to fulfill the processing purposes and due to the nature of many of the services offered by the Enroush Site, the Company may disclose your Personal Data to partners, third parties, or entities that support the Company in carrying out its activities, as well as to public authorities at their legitimate request. By providing us with your Personal Data, you agree to their use and disclosure in this manner.

We may share or transfer your Personal Data with our subsidiaries operating other websites of the ENROUSH brand so that they can send you information about their products or services that may be of interest to you.

We collaborate with third-party companies that help us provide and improve our services or use our advertising products or associated products. We transfer information to merchants, service providers, and other partners for technical infrastructure service solutions, analyzing how our services are used, measuring the effectiveness of our ads and services, providing customer support, facilitating payments, or conducting surveys and research. Thus, we disclose personal information to our service providers to the extent reasonably necessary or appropriate to provide the services offered on the Company's Site. Our service providers are legally obligated to protect your Personal Data. Since many of the Company's websites operate or use service providers located in different countries, your Personal Data may be transferred to a country where you do not reside, and while you are in that foreign country, it may be accessible to its authorities.

We may be required to disclose your Personal Data to comply with a court decision, subpoena, search warrant, or a legal request from public authorities, including for national security or law enforcement requirements. In addition, we expressly reserve the right to disclose your Personal Data when we believe in good faith that disclosure is necessary to protect our rights, enforce our agreements, policies, and rules governing the use of the Enroush Site, and/or report information about a serious threat of bodily harm or death.

We do NOT sell or rent any of your Personal Data to third parties for marketing purposes without your express permission or consent. However, we may disclose certain aggregated or encrypted information to third-party advertisers in a manner that no longer reflects or refers to an individually identifiable user, for other marketing and promotional purposes.

When you provide us with your Personal Data, including sensitive information, you agree to our use and disclosure of this information as described in this Policy. If you do not want us to use or disclose your Personal Data as described in this Policy, please do not provide it to us. Please note that this may result in your inability to access some or all of our services.

If there is a change in ownership or partial or total control over our services and associated assets, we may transfer your information to the new owner.

You do not have the right to use other users' information on the Enroush Site, whether private or not, for commercial purposes, to send spam, or to engage in harassment or make illegal threats.

8. Transfer of Personal Data
Personal data provided to the Company may be transferred outside of the United Arab Emirates. When visiting any of the Company's websites, you should be aware that your Personal Data may be transferred, stored, and processed in the United States of America or other countries related to the Company or its service providers.

Data protection and other laws in the United States and these other countries may not be as comprehensive as those in your country, and your personal information may be accessible to law enforcement authorities in the United States or other countries.

In cases where it is necessary and within the context of the Company's activities and operations, the transfer of Personal Data outside the European Union is permitted with effective protection for their processing and with all necessary measures taken in front of the Data Protection Authority, before the actual data transfer, in those areas where, according to the aforementioned regulation, prior authorization from the competent authority is required regarding the data transfer.

In this case, our data transfers, in accordance with GDPR, are carried out to ensure that your Personal Data are adequately protected through standard data protection clauses adopted by the European Commission under Article 46(2) of the GDPR.

9. Your Rights
You have the right to inquire in writing whether we hold Personal Data about you and to see this information, as well as how we collect, use, or disclose it. Therefore, under the legislation on the processing of personal data, as a data subject, you have the following rights:

- Right to information - namely the right to receive details regarding the processing activities carried out by the Company as described in this document;

- Right of access to data - namely the right to obtain confirmation from the Company regarding the processing of Personal Data, as well as details concerning the processing activities such as how the data is processed, the purpose of processing, recipients, or categories of recipients of the data, etc. Furthermore, you have the right to obtain a copy of the data we have about you. Please note that we may not be able to provide you with all the information you request, depending on circumstances (e.g., if they contain Personal Data of other data subjects, users of the Enroush Site). There may be a fee for any copy of personal information requested;

- Right to rectification - namely the right to obtain the correction, without undue delay, by the Company of inaccurate/unjustified Personal Data, as well as the completion of incomplete data. The rectification/completion will be communicated to each recipient to whom the data has been transmitted, unless this proves impossible or involves disproportionate effort;

- Right to erasure of data - without undue delay, ("right to be forgotten"), in case one of the following reasons applies: (i) they are no longer necessary for the purposes for which they were collected or processed; (ii) if consent is withdrawn, and there is no other legal basis for processing; (iii) if the data subject opposes the processing, and there are no legitimate grounds that override; (iv) if personal data has been processed unlawfully; (v) if personal data must be erased for compliance with a legal obligation; (vi) personal data has been collected in connection with the provision of information society services pursuant to Union law or national law under which the operator is located;

It is possible that, following your request for data erasure, the Company may anonymize this data (thus removing its personal nature) and continue to process it for statistical purposes;

Please note that, despite your request, we may retain certain Personal Data (including credit card information) in our files if necessary for: (a) resolving disputes; (b) complying with agreements, rules, or regulations regarding credit card commerce; (c) improving security, reducing fraud of any kind, and ensuring compliance with legal provisions; (d) applying any agreements, policies, rules governing the use of the Company's websites;

We would like to inform you that despite our efforts to delete your Personal Data from our database at your request, the deleted information may exist in backup copies or in the cache memory of other users. For example, an exchange of information with another user of the Site may remain in their computer's cache memory.

- Right to restriction of processing - to the extent that you have doubts about the accuracy of your Personal Data, as well as in other cases provided by law;

- Right to data portability - namely (i) the right to receive Personal Data in a structured, commonly used, and machine-readable format, and (ii) the right for this data to be transmitted by the Company to another data controller, to the extent that the conditions provided by law are met;

- Right to object - namely the right to object to the processing of Personal Data based on a legitimate legal basis considered by the Company. In addition, you have the right to object at any time to the processing of Personal Data for direct marketing purposes;

- Right not to be subject to automated individual decision-making - namely the right not to be the subject of a decision based solely on automated processing activities, including profiling, which produces legal effects concerning the data subject or similarly significantly affects them;

- Right to address the National Authority for Personal Data Processing Supervision or the competent courts - to the extent that you consider it necessary;

For all requests related to access, update, modification, or deletion of Personal Data, please send us an email at privacy@enroush.com or a written communication to PWR HUB DMCC, Unit No: 3O-01-BA1123
Jewellery & Gemplex 3, Plot No: DMCC-PH2-J&GPlexS, Dubai, United Arab Emirates;

You have the right to contact us using the above contact information to file a privacy-related complaint. We will explain our procedure and investigate all complaints received. If a complaint is justified, we will take all appropriate measures to correct the situation. We will also notify you of any other available procedures.

10. Use of Websites by Minors
The Company's websites are intended for individuals aged 18 and over. Children under the age of eighteen are prohibited from using Enroush Sites or services.
We request that individuals under the age of 18 do not provide Personal Data through ENROUSH Sites. We reserve the right to request proof of parental consent at any time to allow the processing of Personal Data related to minors.

11. Data Security
The Company will take appropriate security measures, including informing and training employees, to protect Personal Data against threats such as:
- Accidental loss or theft;
- Unauthorized access, use, or disclosure;
- Copying, altering, falsifying, or unauthorized modification of data;
- Illegal or unauthorized data retention;
- Accidental or unlawful destruction.

The Company regularly conducts checks on procedures related to the collection, storage, and processing of Personal Data to ensure the effectiveness of data protection measures.

Employees of the Company will take appropriate measures to prevent improper use or loss of Personal Data and to prevent unauthorized access to it. Employees will report any instances of improper or suspected improper use, loss, or unauthorized access to the administrator.

Please DO NOT post, share, or disclose any Personal Data on public forums (e.g., chat rooms, blogs) that you do not want other users to know. We encourage you to ask questions before disclosing your information. Similarly, you should not disclose or share your user account password with anyone else.

If you lose control of your account password, you may lose substantial control over Personal Data, and you may be subject to legally binding actions taken on your behalf. If your account password has been compromised for any reason, you should immediately change your password and/or contact us at: privacy@enroush.com.

For any additional questions regarding how Personal Data is processed and to exercise the rights mentioned above, please send an email request to: privacy@enroush.com.

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