1. Introduction

In accordance with the details outlined in Brooj’s Terms of Service, hereinafter referred to as “Brooj,” we offer web hosting, domain name registration, and associated products and services to our customers and subscribers, collectively referred to as “You” or “Users.” Brooj is dedicated to upholding the highest standards of data privacy as we deliver a diverse range of quality offerings to our clientele.

At Brooj, safeguarding the privacy and security of our Users is our utmost priority. We are committed to ensuring the protection of the data you entrust to us. In this Privacy Policy (“Policy”), when we use terms such as “Brooj,” “we,” “us,” or “our,” we are referring to Brooj, the entity responsible for safeguarding your personal information in accordance with this Privacy Policy, acting as the Data Controller.

This Policy elucidates how Brooj handles information, both directly and indirectly identifying individuals, referred to as “Personal Data,” collected on our website, our services (“Service”), forums, and mobile applications (“Platform”). All personal data is processed in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”). For inquiries regarding this Policy or requests concerning the processing of personal data, please contact us at gdpr@Brooj.net.

      1. General Principles. Confidentiality

Brooj is committed to processing all Personal Data in adherence to the following general data processing principles:

      • Lawfulness, fairness, and transparency: Personal Data is processed in a lawful, fair, and transparent manner in relation to the data subject.
      • Purpose limitation: Personal Data is collected and processed solely for specified, explicit, and legitimate purposes and is not further processed in a manner inconsistent with those purposes.
      • Data minimization: Personal Data is maintained at an adequate, relevant, and minimal level necessary for the intended purposes.
      • Accuracy: We ensure that Personal Data is accurate and, where necessary, kept up to date.
      • Storage limitation: Personal Data is retained only for the duration necessary for the purposes for which it was processed.
      • Integrity and confidentiality: Personal Data is processed with the utmost care for security, protection against unauthorized or unlawful processing, and safeguarding against accidental loss, destruction, or damage through appropriate technical and organizational measures.
      • All information stored on Brooj’s Platform is treated as strictly confidential, securely stored, and accessible only to qualified and authorized personnel.
      1. Information We Collect

3.1. Information You Provide to Us

      • We collect the following personal information about you when you utilize the Brooj Platform, which is essential for the performance of the contractual arrangement between you and us and to comply with legal obligations. Failure to provide this data may result in the deactivation of your Brooj Account.
      • Account Signup Information: To create an account with Brooj, we require minimal information such as your email address and password. In specific cases, additional information like your first and last name, identity verification, and contact details may be requested, especially when registering a domain name (WHOIS information).
      • Login Information: We collect Login scope and Email scope from Google and email from Facebook.
      • Identity Verification: To meet ICANN rules, we may collect identity verification information, including images of official documents like passports, national ID cards, or driving licenses as required by applicable laws.
      • Payment Information: For ordering and using Brooj Platform features, such as web hosting and domain name registration, we may request financial information to facilitate payment processing. Please note that we do not store credit card information; we receive payment status information and retain only the last four digits of credit card numbers.
      • Communications, Chats, Messaging: When you communicate with Brooj, we gather information related to your communication and any data you choose to provide. This includes information in your Brooj Account, purchase history, and more, to address your inquiries.
      • Job Applicants’ Information: Information submitted when applying for career positions is collected, as detailed in Section 5.
      • Visitors and Users of Our Users’ Websites or Services: Information about visitors and users of our Users’ websites or services may be collected solely on our Users’ behalf.

You may also voluntarily provide us with information through forms, searches, updates to your Brooj Account, surveys, community forums, promotions, or other Brooj Platform features. We advise against sharing any information on the Brooj Platform that you do not wish to make public. Any content uploaded or shared on your account is at your own risk.

Brooj processes information based on the legal basis of your consent, contractual arrangements, legitimate interests, and legal obligations, including ICANN rules.

Disclaimer

Please exercise caution and adhere to the following minimum requirements to protect your personal information:

      • Avoid including personal identifiers such as name, address, phone number, email, identification numbers, and financial data in the subject or file name of your correspondence.
      • Refrain from disclosing sensitive information in your requests, emails, or other communications.
      • Ensure that any remaining personal data shared is limited to what is necessary for the communication’s purpose.

Right to Delete Your Data

You can access, edit, update, or delete your contact details within your Brooj Account at any time. To deactivate your Account and delete your email, please contact gdpr@Brooj.net for guidance.

Information Related to Calls or Meetings

When you call Brooj or schedule a meeting, we may record these conversations for quality management purposes. This data includes email address, date, time, duration of the conversation, audio and/or video recordings, and any other voluntarily provided personal data during the conversation. The processing of this data is necessary for the legitimate interests pursued by Brooj or based on your consent.

Recordings are retained for up to 30 days and deleted thereafter as soon as technically feasible.

3.2. Information We Collect When You Use the Platform

When you use the Brooj Platform or contact us directly, we may collect information, including personal information, about the services you use and how you use them. This data is essential for contract performance, legal compliance, and enhancing Brooj Platform functionalities.

Automatic Collection of Data

      • Log Data and Device Information: We automatically collect log data and device information when you access and use the Brooj Platform, including IP addresses, browser types, ISPs, referring/exit pages, operating systems, and timestamps.
      • Tracking Technologies and Cookies: We use various technologies like cookies, beacons, tags, scripts, and more, as well as collect device information such as operating systems, phone models, device IDs, and customer numbers. For detailed information, please refer to our Cookies Policy.
      • Usage Information: We employ Google Analytics to gather insights into your interactions with the Brooj Platform, such as the pages you visit, content viewed, searches conducted, bookings made, and other activities. Google, Inc. utilizes permanent cookies to identify you as a unique user during future visits to the Site.
      • Geo-location Data: We collect approximate location data based on your IP address to enhance user experiences and comply with legal requirements, such as taxes and pricing, only when you access the Brooj Platform using your device.

Adhere to relevant legal obligations, including taxation and pricing, etc. This information can only be gathered when you access the Brooj platform through your device.

Brooj handles this information based on:

      • Your explicit consent.
      • The necessity to fulfill contractual agreements and obligations between Brooj and the User.
      • Pursuance of Brooj’s legitimate interests as the Data Controller and manager of the Brooj platform.
      1. How We Use Your Data

We utilize, store, amalgamate, and process information, including personal information, pertaining to you for several purposes:

      • To Identify: Personal identification details are gathered and processed for user identification purposes and for the utilization of services, including domain name registration. Additionally, this data may be employed to offer support, communicate upcoming updates or enhancements, relay information regarding changes to our Terms of Use (including revisions to this Policy), and other significant notices.
      • To Create and Maintain a Trusted Environment: We verify or authenticate the information or identifications provided by you, such as ID numbers, email addresses, or phone numbers. We also employ collected information to detect and prevent fraud, spam, abuse, security incidents, and other illicit and harmful activities.
      • To Create Aggregated Statistical Data: For running our business and enhancing our services, we use aggregated and/or inferred non-personal information to evaluate customer needs, sales, and other activity trends.
      • To Stay Connected: We employ information on data usage, devices, and operating systems to diagnose server issues, administer our Platform, make decisions on retiring SDKs/OS versions, identify characteristics of major users to optimize our applications and services, and enhance your browsing and purchasing experience.
      • To Customize Marketing: To provide more personalized offers to our Users, we may conduct data analysis based on information you provide, your interactions with the Brooj Platform, and interactions with other Users.
      • To Send Service and Billing Messages: Brooj may contact you with essential information regarding our services or your usage thereof. For instance, we may notify you (via available communication channels) if a particular service is temporarily suspended for maintenance, respond to support inquiries or emails, send reminders or warnings about upcoming or late payments, forward abuse complaints about your hosting plan, or inform you of material changes in our services. Opt-out options are not provided for these Service and Billing Messages unless you are no longer a Brooj User (achieved by deactivating your Account).
      • To Register Domain: In certain jurisdictions or per ICANN or registry rules, domain name registration information must be publicly accessible through a “WHOIS” search. We store your domain name registration information and make it available to the public through WHOIS searches. Brooj may deposit your domain name registration information with a third-party escrow provider to meet ICANN requirements. Users may receive solicitations resulting from searches of the publicly available WHOIS database by other entities. These solicitations do not originate from Brooj, and Brooj is not responsible for third-party use of WHOIS information. Brooj complies solely with ICANN rules. For more information, see: https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en#whois.
      • To Contact You: We may contact you to notify you about your Account, troubleshoot Account issues, resolve disputes, collect fees or payments, gather opinions through surveys or questionnaires, send company updates, or enforce our User Agreement, national laws, or agreements we may have with you. We may use email, telephone, text messages, and the portal for these purposes.
      • To Get Feedback: Via email, we may invite you to review services or products you received from us to collect feedback and improve our services. External companies may be used to collect your feedback, requiring sharing your name, email address, and reference number.
      • To Provide, Operate, and Improve the Services: Enhance data security and prevent fraud.
      • To Comply with Applicable Laws and Regulations.
      1. Job Applications

Brooj encourages all qualified Applicants to apply for open positions published at https://www.Brooj.net/career by providing their contact details and CV (“Applicants Information”) via the relevant Position Application Form on our Website or through other provided means.

We understand that privacy and discretion are vital for our Applicants. We are committed to keeping Applicants Information confidential and using it solely for Brooj’s internal and group companies’ recruitment purposes. This includes identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants via phone or in writing.

Brooj may retain Applicants Information submitted for up to one year after the applied position has been filled or closed. This information is collected for reconsideration of Applicants for other positions and opportunities at Brooj, using their Applicants Information as a reference for future applications, and for additional employment and business purposes related to their work at Brooj.

If you previously submitted Applicants Information to Brooj but now wish to access, update, or have it deleted from our systems, please contact us at gdpr@Brooj.net.

 

      1. COLLECTION OF INFORMATION RELATING TO VISITORS AND USERS OF OUR USERS’ WEBSITES OR SERVICES

We may gather, store, and process specific information concerning visitors and users of our users’ websites or services, solely on behalf of our users and as per their instructions. Each of our users has the capability to gather and manage information, including personal data, through their websites. This information and personal data are subsequently stored with Brooj. In certain limited cases, as stipulated in the Terms of Service, Brooj, for the purposes of the GDPR, may be considered a “data processor” of this information pertaining to visitors and users of our users’ websites or services. The users who control and operate these websites are regarded as the “data controllers” of such information and bear complete responsibility for complying with all relevant laws and regulations governing its collection and control, including privacy and data protection laws in various jurisdictions.

Users are solely responsible for the security, integrity, and lawful usage of information related to visitors and users of their websites or services. They are also responsible for obtaining consents, permissions, and providing necessary notices for the collection and usage of such information. Brooj does not have a direct relationship with individual visitors and users of our users’ websites or services, whose personal data it processes. If you are a customer of any of our users and wish to make any requests regarding your personal data, please contact the respective user(s) directly. For more information about the data processing arrangement between us and our users, please refer to our Terms of Service.

      1. DIRECT MARKETING AND SERVICE NOTICES/RENEWAL REMINDERS

Upon creating an account on our platform, you have the option, subject to available preferences, to provide consent or opt-out of receiving various offers, notices, and service expiration reminders directly via email, phone (including SMS and/or WhatsApp messages), or within your account. We utilize the provided contact details and your preferences for direct marketing (sending offers or newsletters) and service expiration notices/renewal reminders. Depending on your preferences, this communication may be personalized, taking into account additional information you have provided to us (such as location, social media profile data, purchase history, etc.), or information we have collected or generated from other sources as described below.

Please be aware that if you subscribe to service expiration notices/renewal reminders via SMS/WhatsApp, we reserve the right (though it is not an obligation) to send such notices/reminders for each service.

Right to Object/Revoke Consent: If a user wishes to modify their communication preferences (revoke consent or object), they are free to exercise this option at any time by (1) following the unsubscribe instructions in received emails (typically through a provided link at the bottom of our email) or text messages, (2) visiting and adjusting their personal account settings (communication preferences). You may also opt out of receiving information from us at any time by sending an email to gdpr@Brooj.net.

      1. OTHER UTILIZATIONS OF YOUR PERSONAL DATA
      • Platform Development: We utilize data, including public feedback, for research and development to enhance our platform, ensuring a better, more intuitive, and personalized experience, and promoting membership growth.
      • Customer Support: Data is used to assist users and resolve issues. We employ data, which may encompass your communications, to investigate, respond to, and resolve complaints and problems (e.g., bugs).
      • Aggregate Insights: Data is used to generate aggregate insights, producing and sharing summarized insights that do not identify specific individuals.
      • Security and Investigations: Data is utilized for security, fraud prevention, and investigations. We use your data (including your communications) when necessary for security purposes or to investigate potential fraud or other violations of our Terms of Use or this Policy, as well as attempts to harm our users.
      1. SOURCES OF PERSONAL DATA

We collect and receive your personal data from the following sources:

      • Self (including your device)
      • Social network operators (e.g., Facebook, Google, etc.)
      • Third-party service providers, suppliers, and partners
      • Other legal sources
      1. RETENTION AND DELETION

We typically retain your personal information as long as necessary to provide our services and comply with legal obligations. Once your personal information is no longer required, we will securely delete it. If you wish to stop us from using your personal information, you can request the erasure of your personal information and the closure of your Brooj Account.

After deactivating your account, we will still retain the following data for compliance with applicable legal requirements (e.g., tax, accounting, legal reporting, AML, etc.):

      • Profile with de-personalized information (your email changed to user@deleted.com, name, surname, and contact information erased), including purchased services, login information, payment details, etc.

Please note that we may also retain some of your personal information in certain cases, including:

      • As long as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. If Brooj suspends your Brooj Account for safety reasons, we may retain certain information to prevent you from opening a new Brooj Account in the future.
      • To meet our legal obligations, we may keep some of your information for tax, legal reporting, and auditing purposes.
      • Forum posts or other publicly visible information may remain accessible on the Brooj Platform, even after your Brooj Account is deactivated. However, your identity will be removed from such information. Additionally, some copies of your information (e.g., log records) may remain in our database but without personal identifiers.
      • To resolve disputes, enforce agreements, pursue or protect legitimate interests.
      • For data security purposes, residual copies of your personal information may remain in our backup systems for a limited period.
      • Domain name registration data: At present, we are required to provide personal information about the domain owner to register a domain. This information is public and is displayed in the WHOIS directory. For more information, please visit https://www.icann.org/registrants.
      1. DATA TRANSFERS AND USE OF THIRD-PARTY SERVICES

During the collection and processing of your personal data, we may carry out data transfers to various third parties.

11.1. With Your Consent: We will share your personal data with external companies, organizations, or individuals outside our group of companies when we have obtained your consent.

11.2. Where We Process Your Personal Data: Users’ personal information may be maintained, processed, and stored by Brooj and our authorized affiliates and service providers in various jurisdictions, including GCC and other locations necessary for the proper delivery of our services or as required by law.

Our affiliates and service providers that store or process your personal data on behalf of Brooj are contractually committed to keeping it protected and secure, in accordance with industry standards, regardless of any lesser legal requirements in their respective jurisdictions.

Domain name registration data and identification data are shared with third parties in accordance with ICANN rules. For more information, see https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en#whois.

We may share non-personally identifiable information publicly and with our partners, such as publishers and advertisers, for trend analysis and other purposes. You can find more information about targeted advertising and your opt-out rights on the respective websites of these service providers.

11.3. Data Localization Obligations: If you reside in a jurisdiction imposing “data localization” or “data residency” obligations, requiring the personal information of residents to remain within the territorial boundaries of that jurisdiction, we will maintain your personal information within those boundaries if legally obligated. During this process, we may continue to collect, store, and use your personal information elsewhere.

11.4. Targeting and Advertising: We use services like Facebook and Google, as well as other advertising and marketing tools. Please review the privacy policies of these service providers. For more information on targeted advertising and your rights, visit the respective websites of these service providers – https://lt-lt.facebook.com/policies/ads#; https://policies.google.com/technologies/ads.

11.5. Social Media Features: Our services include Social Media features and widgets, such as “Facebook Connect” or “Google Sign-in,” the “Facebook Like” button, the “Share this” button, or other interactive mini-programs (“Social Media Features”). These may collect information like your IP address or the page you are visiting on our website, and may set cookies to function properly. Social Media Features are hosted by third parties or directly on our services. Your interactions with these Social Media Features are governed by their respective policies.

11.6. Legal Obligation to Use or Disclose Personal Data: We may disclose your Personal Data to state and public authorities without your prior permission if required by law, including taking legal action to defend our rights or responding to lawful requests by public authorities, as well as cases where we have a good faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to comply with applicable laws, regulations, legal processes, or enforceable governmental requests. We may also disclose your personal data if we are legally obligated to do so or with your explicit consent.

      1. SAFETY AND SECURITY

Brooj has implemented a series of security measures intended to safeguard the Personal Information you share with us. These measures encompass physical, electronic, and procedural safeguards. For instance, we provide HTTPS secure access to most areas of our Services. Additionally, we continuously monitor our systems for potential vulnerabilities and threats. We are constantly exploring new methods and third-party services to further enhance the security of our Services and protect the privacy of our Visitors and Users.

However, despite the steps taken by Brooj, it is important to note that we cannot provide an absolute guarantee of the protection and security of your Personal Information or any other User Content that you upload, publish, or share with Brooj or any other party. As such, we encourage you to create strong passwords for your User Account and refrain from disclosing any sensitive information that you believe, if exposed, could cause you significant or irreparable harm. If you have any inquiries regarding the security of our Services, please do not hesitate to contact us at gdpr@Brooj.net.

      1. YOUR PRIVACY RIGHTS

You possess a range of rights related to the protection of your Personal Data, subject to the limitations, restrictions, and conditions outlined in the GDPR and applicable laws. These rights encompass:

      • The right to access the information we hold about you.
      • The right to correct any incorrect or inaccurate information pertaining to you.
      • The right to have all or part of the data collected about you transferred to you or another data controller, where technically feasible (right to data portability, subject to certain limitations and restrictions as specified in the EU General Data Protection Regulation).
      • The right to request the deletion of any data concerning you. Users may request data erasure without undue delay for valid reasons, such as when the data is no longer necessary for its intended purposes or has been processed unlawfully.
      • The right to restrict data processing. Users may obtain the restriction of data processing from the controller for legitimate reasons.
      • The right to object to the processing of Personal Data when such processing is based on legitimate interests, as well as in cases where your personal data is used for direct marketing purposes, as detailed earlier in this Policy.

Exercising some of these rights is straightforward. For instance, you may access, edit, update, or amend your details at any time, opt out of receiving communications from us and our partners by visiting and adjusting your personal account settings, or by emailing us at gdpr@Brooj.net. If you object to the processing of Personal Data based on legitimate interest, we will carefully consider your request, which may result in the closure or deactivation of your Account.

Users also have the right to lodge a complaint with the national Data Protection Agency in their country of residence if they believe their rights may have been infringed. However, we recommend attempting to resolve any disputes by contacting us first.

      1. ACCEPTANCE OF THIS POLICY

We assume that all Users of Brooj Platform have carefully reviewed this document and agreed to its contents. If someone does not agree with this Policy, they should refrain from using our website and mobile applications. We reserve the right to modify our Policy at any time and will inform you through the means outlined in Section 17. Continued use of Brooj’s website and mobile applications implies acceptance of the revised Policy. This Policy is an integral part of Brooj’s Terms and Conditions. We will seek your consent before using information for purposes other than those outlined in this Policy.

      1. CONTACT INFORMATION

For any inquiries or comments related to this Privacy Policy, please reach out to us at gdpr@Brooj.net.

      1. SCOPE OF THIS POLICY

Our Policy applies to all services provided by us and our affiliates, including Brooj, Brooj, a private SPC company organized under the laws of the Sultanate of Oman under code 1461169, but excludes services covered by separate privacy policies that do not incorporate this Policy. Our Policy does not extend to services offered by other companies or individuals, including products or sites that may be presented to you in search results, sites featuring our services, or other websites linked from our services.

      1. AMENDMENTS

Our Policy may undergo periodic changes. We will post any Policy modifications on our website and, in the case of significant changes, may provide more explicit notice (including email notifications for certain services) regarding Policy revisions.

      1. FURTHER DETAILS

If you have additional questions concerning the data collected by Brooj or how we utilize it, please do not hesitate to contact our Data Protection Officer using the contact information provided above.

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