Privacy Policy

Privacy Policy

APP

Consent to installation of the App

Your privacy is important to us.

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in our Privacy Policy and it is important that you read that information.

Before installation of this App, please indicate your consent to our processing of your personal data as described in our Privacy Policy.

YES I consent to the installation of the App and the processing of my personal data for the purposes of accessing the services offered through the App (whether in “continue as a guest” mode or as a registered user).

NO I do not consent to the installation of the App.

How you can withdraw consent

Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us at info@wittosis.com but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Privacy Policy

Introduction

Welcome to WITTOSIS’s privacy policy.

MMK Tech Labs W.L.L (we, us and our) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and/or mobile application (our Platform) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This policy (together with our terms of use and cookie policy) applies to your use of our website www.wittosis.com (Site) and our mobile application software (App), known as WITTOSIS which is made available via the Google Play store and the iTunes store, once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).


This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR RIGHTS

10. GLOSSARY


1. Important information and who we are

MMK Tech Labs WLL is a private limited company, registered in Bahrain under registration number 165719 - 1, and its registered office address is at Unit 53, Building 2415 Road 2831, Block 428 Seef District Kingdom of Bahrain.


WITTOSIS aims to provide a forum for people facing similar mental health challenges to meet with each other, share their experiences, recommendations, insights and understanding for such issues and generally support each other. We do this by enabling people to share their thoughts, feelings, personal health experiences and information with people with similar health conditions online using our Platform.


It is therefore important that you understand how we use and share your information through the use of our Platform.


Purpose of this privacy policy


This privacy policy aims to give you information on how we collect and processes your personal data through your use of our Platform.


It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.


Age Requirements. Our Platform is not available to individuals below the age of 18 We do not knowingly collect information from children under the age of 18 and if you are under this age you must not use our Platform. Please take your privacy seriously and do not provide false information regarding your age when you register. If we become aware that you are under 18 and using our Platform, we will terminate your user account and issue bans to your device.


Controller

MMK Tech Labs WLL is the controller and responsible for your personal data.


If you have any questions about this privacy policy, including any requests to exercise your rights, please contact us at info@wittosis.com.


Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name: MMK Tech Labs W.L.L

Email address: info@wittosis.com


You have the right to make a complaint at any time to the Personal Data Protection Authority) (PDPA), the Bahrain regulator for data protection issues (http://www.pdp.gov.bh/en/index.html). We would, however, appreciate the chance to deal with your concerns before you approach the PDPA so please contact us in the first instance.


Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


Third-party links

Our Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you or plant cookies or other trackers on your device. We do not control these third-party websites, or applications and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every website or app you visit.


2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).


We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes email address and telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform, including cookie data.

• Device Data includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device),] mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.

Profile Data includes your username and password, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our Platform.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences and other communications data such as calls with our support centre, live listening and calls recorded for quality control and training purposes.

Data you provide to us includes the content, communications and other information you provide when you use our Platform, including when you sign up for an account, create or share content (i.e. make a post or create forum), your messages and communications with us and other users of our Platform. This can also include information in or about the content you provide, such as the location of a photo or the date a file was created.

Networks and Connections includes the people, accounts, groups and pages you are connected to and how you interact with them.

Data from other users or third parties includes content, communications and information that other people provide when they use our Platform. Anything we receive from third parties may be combined with information we already hold.


Location Data: includes your current location disclosed by GPS technology. Please note that the data items in the sections above are only considered “personal data” when concerning a natural person (meaning an individual human being). These data items are not considered “personal data” when concerning a legal person or entity.


We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.


We may collect Special Categories of Personal Data about you when you choose to add this information to your profile and when you use the Platform to make a post, comment or enter into private discussions with other users (this includes details about your health or mental health race, or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data). You have the option to share this information with other users of our Platform. You may remove this information from your profile or contributions at any time. We will obtain your consent in collecting this data.


We do not knowingly collect any information about criminal convictions and offences.

Special Categories of Personal Data are subject to additional regulation.


If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us, suspend your access to our Platform, or remove your account registered on our Platform, but we will notify you if this is the case at the time.


3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by email. This includes personal data you provide when you:

• create an account on our Platform;

• subscribe to our service or publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us.

Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

(a) analytics providers such as Google based outside Bahrain;

(b) location data collected via GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings or by contacting us;

(c) Device Data from the following parties:

(i) advertising networks based inside or outside Bahrain;

(ii) search information providers based inside or outside Bahrain;

(d) Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside Bahrain; and


4. Identity and Contact Data from data brokers or aggregators based inside or outside Bahrain. How we use your personal data

We will only use your personal data when the law allows us to and where you have consented to the processing. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

Go to the bottom of this policy TO GLOSSARY, LAWFUL BASIS to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before we collect any special category data and location data or send third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.


Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.


Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.