This privacy notice describes how and why we might collect, store, use, and/or share ("process") your personal information when you interact with us or visit our website (www.hena.work) and/or make use of, download and/or stream HENA applications (“Platform”), and other related applications and services (collectively, the “Services”). Please also read our Terms of Service which sets out the terms governing the Services. In this privacy notice, "HENA", "we", “us” "our" means the HENA group company or companies who are responsible for personal information collected about you in the Kingdom of Bahrain. Depending on your location, a company from the HENA group of companies will be responsible for processing your personal information, either solely or jointly with its affiliates or subsidiaries within the HENA group of companies as follows: § In the Kingdom of Bahrain, the local company responsible for the processing of your personal information is Market Place W.L.L. We may update this privacy notice from time to time and make changes to information previously collected, as permitted by law.
The updated version will be indicated by a revised “Last Updated” date and the updated version will be effective as soon as it is accessible. To the extent required by applicable law, we will notify you in advance of any such changes. In any case, we encourage you to review this privacy notice frequently to be informed of how we are protecting your information. Third party links Our Platform may, from time to time, include links to third-party websites, plug-ins and applications, including those of partner networks, advertisers and affiliates. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these thirdparty websites and are not responsible for their privacy statements or policies. When you leave our Platform, we encourage you to read the privacy policy of every website you visit or application you install or stream before you submit any personal data to these websites or applications.
TABLE OF CONTENTS
1. What Information Do We Collect?
2. How Do We Process Your Information?
3. Our Legal Basis for Using Your Personal Information
4. When And With Whom Do We Share Your Personal Information?
5. Overseas Transfers of Personal Information
6. How Do We Keep Your Information Safe?
7. Do We Collect Information From Minors?
8. What Are Your Privacy Rights?
9. How Long We Retain Your Data
10. How Can You Contact Us About This Notice?
1. What Information Do We Collect? Personal information is any information that relates to you, identifies you personally, or could be used to identify you including, but not limited to: your name, mailing address, email address, telephone number, or any other information. Personal information does not include anonymised or aggregated information. The personal information that we collect depends on the context of your interactions with us and the Services and/or Platform, the choices you make, and features you use. For the purposes of verifying your identity and fraud / identity theft detection purposes, we may collect certain personal information that may fall under ‘special categories of personal data’ or ‘sensitive personal information’ as per the applicable data protection legislation, including your social security number, driver’s license or passport number. We only collect such information about you where we have obtained your consent, or where otherwise have a lawful basis to do so in accordance with applicable laws.
The categories and types of personal information we collect about you includes the following:
(i) Personal information you disclose to us We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you participate in activities on our Platform (including upon the create of an account with us as provided for in our Terms of Service), or when you otherwise contact us.
This may include:
-Contact Information: Postal address, telephone number, email address, contact preferences or other similar information.
-Identity Details: Copy of ID card, passport or driver’s license, social security number, proof of address, and includes data such as first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender etc.
-Account Information: Your username, password and associated account actions, including when an account with us is created, and any changes to your account.
-Transaction Information: Information related to transactions made through the Platform.
-Visual, audio, electronic, or similar data: Physical characteristics or description, video or photos you choose to share with us whether through the Platform or otherwise.
-Financial Information: Bank account number, credit card or debit card details, other financial information.
-Employment and Resume Information: Your work history, education history, employment credentials, certifications, licenses, awards, job preferences and any other relevant data you provide on the Platform.
(ii) Personal information we collect as you use our Services
-User Content: Project and bid descriptions, user profiles, user reviews, user messages etc.
-Platform Usage Information: Browsing history, search history, the dates and times you access our Services and any other information regarding your interaction with the Services and/or the Platform.
-Communications: If you contact us for customer service or to provide feedback, we may receive information such as your name, email address, and phone number. We also will receive the contents of any communications you have with us. This might include requests, questions, and issues regarding your account, our Services, or other topics you might raise.
-Device Information: Device name, type and usage information, such as your IP address, browser type and version, operating system and platform, time zone setting and location, browser plug-in types and versions, language preferences, and other technical information.
(iii) Personal information that we obtain from third party sources. We may receive and collect information about you from third party sources in order to manage your relationship with us (including but not limited to the verification of your identity). We will only use this information where these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. In some situations, personal information of users may be collected from public sources. (iv) Information automatically collected Subject to your device settings, we may be able to collect information about the precise location of your device or may gather other general location data based on GPS data, mailing address, and/or billing address (hereinafter collectively referred to as “Geo-Location Data”), to customise our Services based on your location. You can prevent your device from sharing precise location information, including without limitation some or all of the Geo-Location Data, at any time through your device’s operating system settings. Like many businesses, we may use different technologies such as cookies, web beacons, or other types of small temporary files or web-based tracking technologies to gather certain information. Please refer to our Cookies Policy.
2. How Do We Process Your Information? We process your personal information for a variety of reasons, depending on how you interact with our Services and/or Platform, including:
-To deliver and facilitate delivery of Services to the user. We may process your information to provide you with the requested service, which may include doing the following: o create and authenticate your account on our Platform, including verification of your identity. o give you relevant search results, job recommendations, and otherwise tailor the content we display to you. o match freelancers with client job / project listings. o facilitate communication as part of the job search, application and interview processes. o facilitate payment, in connection with chargeable services. o make your profile available to third parties (depending on your privacy settings).
-To provide technical or other support to you. We may process your information to respond to your inquiries, complaints and/or solve any potential issues you might have on our Platform.
-To send you marketing and promotional communications. We may process your personal information for marketing purposes and specifically to promote our other programs or services which may be of interest to you (unless you have opted out from such communication – please see "What Are Your Privacy Rights?" below).
-To deliver targeted advertising to you. We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more. If we process your personal information for targeted advertising, including for profiling, we will inform you of this separately, to the extent required by applicable law. You have the right not to be subject to a decision based solely on automated processing and can object to this type of processing (see “What Are Your Privacy Rights?” below).
-To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
-For Security purposes. We may process information for security purposes or to prevent or investigate possible fraud or other violations of our policies or Terms of Service and/or attempts to harm other users on the Platform. To the extent permitted by law we may anonymise, aggregated or otherwise de-identify your personal information for the purpose of compiling industry, marketing and employment statistics or insights that we may use or share (“Aggregated Data”). 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 Platform Usage Information 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 notice.
3. Our Legal Basis for Using Your Personal Information Our legal basis for collecting and using your personal information as described in this privacy notice, will depend on the personal information concerned and the specific context in which we collect it. We will comply with the applicable data protection legislation. In general, we collect and process your personal information on one or more of the following legal bases:
-Your consent, for example where we have obtained your consent to process your personal information for certain activities. You may withdraw your consent at any time by contacting us using the contact details provided in the section “How Can You Contact Us About This Notice” below.
-To provide the Services and perform our obligations in accordance with the Terms of Service. For example, we cannot provide the Services unless we collect and process certain personal information about you.
-For our legitimate business interests, or sometimes where it is necessary for the legitimate interests of another person, provided that we have balanced these against your fundamental rights and interests. Legitimate business interests means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
-For compliance with our legal obligations to ensure that we comply with all statutory and regulatory requirements within the jurisdictions within which we operate (including those relating to bribery and corruption, money laundering and sanctions), and to also exercise, prepare for or defend actual or anticipated legal claims.
4. When And With Whom Do We Share Your Personal Information? We share your personal information with HENA’s affiliated companies, service providers or other third parties where it is necessary to perform the Terms of Service and as described in this privacy notice. In particular, we may share your information with:
-Clients. We may send freelancer personal information to clients on the instruction of freelancers. Such data disclosure is performed in the course of the job search, application and interview process. Such personal information will be processed in accordance with these terms and those of the relevant client.
-Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
-Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our group company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
-Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
-Government, Regulatory and Law Enforcement Agencies. We may share your information if we believe in good faith that it is reasonably necessary to do so for legal reasons, including to meet federal, state, regulatory or local law requirements or as part of a judicial process or to detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues or to prevent harm or injury to you, members of the public, our staff, other third parties, or ourselves; or if we need to do so to defend our legal rights or property, to take action regarding illegal activities or traffic offenses, or to enforce our contracts, such as our Terms of Service. We may also share your information with competent regulators and other authorities who require reporting of processing activities in certain circumstances.
-Our Service Providers and Partners. We share your information with our trusted service providers, partners, and their personnel who provide services to HENA. These include cloud hosting, storage and related providers, providers of ID verification services, payment processing providers, security providers, and marketing and analytics providers. For example, we share information with credit card issuers in order to process your payments and refunds.
-Professional advisers. We may share your information with our professional advisors including lawyers, bankers, auditors and insurers who provide us with consultancy, banking, legal, insurance and accounting services. Such professional advisors may be located in your country or in other jurisdictions, including Bahrain, Spain and the United Kingdom. Please refer to section 5 below on ‘Overseas Transfers of Personal Information’. We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
5. Overseas Transfers of Personal Information We may share your personal information with companies within the HENA group and/or third parties as described under section 4 above. Sometimes when we share your personal information in such manner, it may be transferred to a country located outside of your country. We will only transfer your personal information to a country located outside your country where we have your consent, or otherwise where we are permitted by applicable laws. Whether the personal information you provide to us is processed by us or third parties within your country or outside of it, we will take steps to ensure that your personal information will be afforded the level of protection required of us under and in accordance with this privacy notice and applicable data protection laws. Where legally required, we will use an adequate transfer method. For example, whenever we transfer your personal information from the EEA to a third party country, we use standard contractual clauses approved by the European Commission which give personal information the same protection it has in Europe.
6. How Do We Keep Your Information Safe? We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process from accidental loss and unauthorised access. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Platform is at your own risk. If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately by contacting us using the details provided at the end of this notice. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your information transmitted from you to us. Any payment transactions will be encrypted using SSL or other encryption technology, or will use our third-party payment processors, who will use appropriate security procedures. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. You should only access the Platform within a secure environment. You should not share your password with anyone.
7. Do We Collect Information From Minors? We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you warrant and represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will cease our Services in accordance with our Terms of Service and take reasonable measures to promptly delete such relevant data from our records.
8. What Are Your Privacy Rights? Depending on where you live or reside, you may have certain rights with respect to your information. Specifically, you may have some or all of the following rights:
-The right to request details of the personal information we hold and process about you (including information regarding how your information may be shared).
-The right to request that we correct or update the personal information we hold about you.
-The right to request that we limit or restrict the personal information we hold about you.
-The right to request that we delete your personal information in certain cases.
-The right to receive your personal information in a structured, commonly used and machinereadable format, and to request that we transfer it to a third party in certain cases.
-The right to object to our processing of your personal information where we process your information based on legitimate interests.
-The right to object to important decisions we make about you that are based solely on automated decision-making / automated processing of your personal information.
We generally do not make decisions based solely on automated processing of your personal information, but when we do so, we will let you know.
The right to lodge a complaint with your local data protection authority: o Kingdom of Bahrain: the Personal Data Protection Authority Withdrawing your consent: If we are relying on your consent to process your personal information,, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us by using the contact details provided in the section “How Can You Contact Us About This Notice” " below. However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Opting out of marketing and promotional communications: From time to time we may send you messages or updates about HENA, our promotions or other activities. If you do not wish to receive nontransaction/non-security related communications from us, you may opt-out by clicking the “unsubscribe” link in the communication you received from us, or send an email message to stating that you no longer want to receive these communications (“Opt-Out”). You will then be removed from the marketing lists as soon as practicable, but in any case, within ten (10) business days commencing from the date of receiving the Opt-Out request. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. Please refer to our Cookies Policy for further information on our use of cookies.
9. How Long We Retain Your Data We will process and store your personal information for as long as it is necessary in order for us to fulfil the purposes for which your personal information has been collected as outlined in this privacy notice (unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When your personal information is no longer required for the purpose it was collected or as required by applicable law, it will be deleted or anonymised. In general, any personal information that is required for the purposes of concluding or executing an agreement with you, will be held during the duration of the contractual relationship and up to 10 years after.
10.How Can You Contact Us About This Notice? To exercise any of your rights or if you have any questions or complaints about this privacy notice please email by writing to . You may also contact us at: