DALAA (PTY) LTD (‘’DALAA’’)

PRIVACY POLICY

Effective: February 26, 2024

Welcome to Dalaa Privacy Policy. This Policy explains how we collect and use your data and how you can control your information.

Transparency is one of our core values at Dalaa. We believe there shouldn’t be any surprises about the data we collect and how we use it — that’s why we’re upfront with how we process it. For example, we process your information to provide you a more personalised experience, including to show you content and information that is most relevant to your experience, as well as more relevant advertisements. Understanding your interests and preferences help us provide a better product experience.

Furthermore, we believe a personalised experience should not come at the expense of your privacy. We delete content by default and to give Dalaa control by providing the tools that allow them to decide what happens with their content, like who to share it with or when to save it.

This Policy covers our Dalaa app as well as our other products, services, and features and our advertising and commerce initiatives. When you read “Services” in this Policy, we’re talking about all of them. Also, if you see us refer to our “Terms,” we mean the Terms of Use that you agree to when you sign up for our Services.

Control Over Your Information

Control over your information and settings is a core part of Dalaa experience. Here, we give you more details on the types of settings that are available, link out to our data download tool, and provide instructions on how to delete data or your account.

We want you to be in control of your information, so we provide you with a range of tools, including:

Access and update your information. You can access and edit most of your basic account information right in our Services. Just navigate to your settings and you will see the options available to you.

Delete your information. If you want to delete your account, learn how here. You can also delete some information within our Services, like content you’ve saved to Memories, content you’ve shared with My AI, Spotlight submissions, and more.

Control who can see your content. We’ve built a number of tools that let you choose who you share your content with. In some cases you may want to share content with your friends, and in other instances you may want to share it with the public. To learn more, go here.

Information We Collect

This section provides you with details on what information we collect. We’ve organised this in a few categories: information you provide to us, information we generate based on your use of our Services, and information we receive from others. Sometimes, we may also collect additional information, with your permission.

When you use our Services, we collect information you provide to us, generate information when you use our Services, and in some cases receive data from others. Let’s break these down in more detail.

Information You Provide

Many of our Services require you to set up an account. To do this, we ask you to provide us with account details (information about you, like your name, username, email address, birthday, and phone number). When you set up your profile, you’ll also provide us with profile details. If you use our commerce products to buy something, we may ask you for payment and related information (like your physical address, so we can ship the product to you, payment information, so we can process the payment, and transaction history).

Information We Generate When You Use Our Services

When you use our Services, we collect information about which of those Services you’ve used and how you’ve used them. This helps us better understand the way our community uses our Services so that we can make improvements.

This includes usage information (information about how you interact with our Services — for example, which Lenses you view and apply, Stories you watch, and how often you communicate with other Dalaa Users) and content information (information about content you create or provide, your engagement with the camera and creative tools, your interactions with My AI, and metadata — for example, information about the content itself like the date and time it was posted and who viewed it). Content information includes information based on the content of the image, video, or audio..

This also includes device information (such as your hardware or software, operating system, device memory, advertising identifiers, apps installed, browser type, information from device sensors that measure the motion of your device or compasses and microphones, including whether you have headphones connected, and information about your wireless and mobile connections), location information (IP address), information collected by cookies and similar technologies, depending on your settings, (cookies, web beacons (small graphic data that recognize user activity, such as if and how often a user has visited a website), web storage, unique advertising identifiers), and log information (such as details about how you’ve used our Services, access times, pages viewed, IP address, and unique identifiers like cookies).

If you’ve explicitly granted device-level permissions, device information may also include information about your device phonebook (contacts and related information), images and other information from your device’s camera, photos, and microphone (like the ability to take photos, videos, view stored photos and videos, and access the microphone to record audio while recording video), and location information (precise location through methods like GPS signals).

Data We Receive From Others

The last category of data we collect is information about you that we may receive from others, such as other users, our affiliates, and third parties. This includes linked third-party service data (information we get when you link your Dalaa account to another service), data from advertisers (information from advertisers, app developers, publishers, and other third parties to help target or measure the performance of ads), contact info from other Dalaa Users or third parties (if another Dalaa User uploads their contact list which includes your information, we may combine that with other information we have about you to better understand who you may want to communicate with. Or, if you provide us with your contact information, we may use that to determine if we can communicate with you in other ways, like SMS, email, or other messaging services), and data relating to potential violations of our Terms (we may receive information from third parties, including website publishers, social network providers, law enforcement, and others, about potential violators of our Terms of Service and Community Guidelines).

Other Information, With Your Permission

Additionally, there may be instances when you interact with our Services that we will ask your permission to collect additional information. For example, before accessing your device’s camera roll or Contact Book.

How We Use Information

This section explains how we use the information we collect. Among other things, we use the information we collect to provide you with personalised products and Services that we work hard to build and improve.

Develop & Improve Features, Algorithms & Machine Learning Models

Our teams are constantly coming up with new ideas for features and ways to improve our Services. In order to do this, we also develop and improve the algorithms and machine learning models (an expression of an algorithm that combs through significant amounts of data to find patterns or make predictions) that make our features and Services work, including through generative AI features (artificial intelligence capable of generating text, images, or other media, using generative models. Generative AI models learn the patterns and structure of their input training data and then generate new data that has similar characteristics). We use algorithms and machine learning models for personalization, advertising, safety and security, fairness and inclusivity, augmented reality, and to prevent abuse or other Terms of Service violations.

Your information can help us decide what kind of improvements we should make, but we are always focused on privacy — and we don’t want to use more of your personal information than necessary to develop our features and models.

Analytics

In order to understand what to build or how to improve our Services, we need to understand trends and demand for our features. For example, we monitor metadata and trends about Dalaa use to help decide whether we should change parts of the feature. Studying data from Users can help us see trends in the ways that people use the Services. This helps inspire us to improve Dalaa on a larger scale. We perform analytics in order to identify, monitor, and analyse trends and usage. Based on this information, we will, among other things, create information about our users to help us understand demand.

Research

We conduct research to better understand general consumer interests, trends, and how our Services are used by you and others in our community. This information, along with analytics (as we described above), helps us understand more about our community and about how our Services fit into the lives of those in our community. We also engage in research and development to develop new techniques and technologies (e.g., new machine learning models or hardware, such as Spectacles). The results of our research are sometimes used in features on Dalaa, and we sometimes publish papers about things like overall behaviours and consumer trends (which will only have aggregated data across our user base, and not contain any private information about you specifically).

Enhance the Safety & Security of Our Services

We use your information to enhance the safety and security of our Services, verify User/s identity, and prevent fraud or other unauthorized or illegal activity. For example, we provide two-factor authentication to help protect your account and can send you email or text messages if we notice any suspicious activity. We also scan URLs sent on Dalaa to see if that webpage is potentially harmful, and can give you a warning about it.

Contacting You

Sometimes we’ll get in touch with you to promote new or existing features. This includes sending Users communications through Dalaa, email, SMS, or other messaging platforms, where permitted. For example, we may use the Dalaa app, email, SMS, or other messaging platforms to share information about our Services and promotional offers that we think may interest you.

Other times, we need to communicate with you to provide information, alerts, or to send messages our users ask us to deliver at their request. This may include sending communications through Dalaa, email, SMS, or other messaging platforms, where permitted, to deliver account status updates, security alerts, and chat or friending reminders.

Support

When you ask for help, we want to get you support as quickly as possible. In order to provide you, the App community, and our business partners with the help needed to resolve issues with our Services, we often need to use the information we have collected to respond.

Enforce Our Terms & Policies

We use the data we collect to enforce our Terms and the law. This includes enforcing, investigating, and reporting conduct that violates our Terms, policies, or the law, responding to requests from law enforcement, and complying with legal requirements. For example, when unlawful content is posted on our Services, we may need to enforce our Terms and other policies. In some cases, we may also use or share your information to cooperate with law enforcement requests, escalate safety issues to law enforcement, industry partners, or others, or comply with our legal obligations.

How We Share Information

This section explains who we share information with, what that information may include, and the reasons for sharing that information, including when we need to transfer it outside of the country it was collected from.

Recipients & Reasons for Sharing

Service Providers. We share information about your activity with our service providers, who process that information on our behalf. For example, we rely on such Service Providers to facilitate payments or measure and optimize the performance of ads. We do not share private communications with them.

Legal, Safety, and Security Partners. We share information about your activity as necessary for the following legal, safety, and security reasons:

• comply with any valid legal process, governmental request, or applicable law, rule, or regulation.
• investigate, remedy, or enforce potential Terms of Service and Community Guidelines violations.
• protect the rights, property, or safety of us, our users, or others.
• detect and resolve any fraud or security concerns.

Affiliates. Dalaa is a subsidiary company within a Group. We may share your information within the Group as needed to carry out our Services.

For the purposes of a Merger or Acquisition. If we were to sell or negotiate to sell our business to a buyer or possible buyer, we may transfer your personal information to a successor or affiliate as part of that transaction.

Integrated Partners. Our Services may contain content and integrations offered by our integrated partners. Examples include integrations in Lenses, Camera editing tools, to provide Scan results, and third-party developer integrations. Through these integrations, you may be providing information to the integrated partner as well as to Dalaa. We are not responsible for how those partners collect or use your information. As always, we encourage you to review the privacy policies of every third-party service that you visit or use, including those third parties you interact with through our Services.

How Long We Keep Your Information

In this section we provide you with information on how long we keep your information, why we keep your information, and also highlight how we may need to keep your information to comply with laws, courts, and other obligations.

As a general rule, we keep information as long as you tell us to, and otherwise as long as we need it to provide our Services, or as required by law. Our systems are designed to delete chats you send within 24 hours after your friend reads it (or automatically after viewing — depending on your settings). Whether we retain your data depends on the specific feature, your settings, and how you’re using the Services. Here are some more factors we consider when we decide how long to keep your information:

If we need the information to operate or provide our Services. For example, we store your basic account details — like your name, phone number, and email address — to maintain your account.

The information itself. For example, we store location information for different lengths of time based on how precise it is and which Services you use. If location information is associated with Dalaa — like those saved to Memories or posted to Dalaa — we’ll retain that location as long as we store the Dalaa Pro tip: You can see the location data we retain about you by downloading your data.

How long we need to retain the information to comply with certain legal obligations.

If we need it for other legitimate purposes, such as to prevent harm, investigate possible violations of our Terms of Use or other policies, investigate reports of abuse, or protect ourselves or others.

Although our systems are designed to delete some of your information automatically, we cannot promise that deletion will take place by a specific time.

In some cases we need to comply with legal requirements to store your data which stops us from deleting your information. For example, if we receive a notice from a court asking us to keep a copy of your content. Other reasons we may be required to keep a copy of your data are if we get reports of abuse or other Terms or policy violations, or if your account, content created by you, or content created with other Users is flagged by others or our systems for abuse or other Terms or policy violations. Finally, we may also keep certain information in backup for a limited period of time or as required by law.

Our Audience

Our Services are directed to individuals 13 years and older.

Our Services are not directed to children under the age of 13, and you must confirm that you are 13 years or older in order to create an account and use our Services. If we have actual knowledge that you are under the age of 13 (or the minimum age at which a person may use the Services in your state, province, or country without parental consent, if greater), we will stop providing Services to you and delete your account and data.

Updates to the Privacy Policy

We may update our Privacy Policy from time to time, and will notify you if we make any changes we think you should know about.

We may change this Privacy Policy from time to time. But when we do, we’ll let you know one way or another. Sometimes, we’ll let you know by revising the date at the top of the Privacy Policy that’s available on our website and mobile application. Other times, we may provide you with additional notice (such as adding a statement to our websites’ homepages or providing you with an in-app notification).