Privacy Policy

We are committed to respecting your privacy and protecting your personal information.

This Privacy Policy applies to the personal information that we collect, use and otherwise process as part of the DuCIRCLE REWARDS Programme, when you use our website or mobile applications or when you contact our customer service representatives by email, telephone and all other means.

What information will we use?

By becoming a member of the DuCIRCLE REWARDS Programme, we will collect and use information about you, the use of your Programme account, shopping purchases and other information that you give us or that we collect. We will have access to your transaction data for purchases you make using our Programme Partners products and services whether it is a credit, debit or prepaid card, eWallet, ecommerce website and others applicable methods. This is in order to offer you points, the opportunity to redeem those points, and provide you with tailored discounts and/or gifts.

In addition, we may receive personal information about you from third parties, such as:

  • Companies contracted by us to provide services to you
  • Companies that participate in our schemes
  • Companies who provide us with your information if you have given prior authorization

What do we mean by personal information?

Personal information means details which identify or could be used to identify you, such as name, contact details and purchase history.

What do we use your information for?

We, companies participating in the DuCIRCLE Programme, and other organisations and service providers that we work with or partner with from time to time, may use your information to:

  • Operate the DuCIRCLE Programme, for example to enable you to collect and redeem Points, provide other programme-related services and ensure that the applicable terms and conditions are observed;
  • Analyse how you use the DuCIRCLE REWARDS Programme and our marketing channels such as our website and our app;
  • Assess the effectiveness of our marketing activities and the marketing activities we carry out on behalf of companies participating in the DuCIRCLE Programme;
  • Understand your behaviour based on the information available to us and to send or show you information, offers, surveys and online advertisements for the products or services which we believe are most likely to interest you.

Automated Processing/Profiling

One of the benefits of being part of the DuCIRCLE Programme is that we can show or send you offers or adverts that are relevant to you by various channels, including the app, text message, and email. We decide what offers and adverts to show or send you using an automated decision-making process which takes into account:

  • The information you have provided to us as part of your participation in the Programme, including, amongst other things, purchases you have made using our Partners payment methods or services
  • Information obtained from third party sources, as identified in “What information will we use”.

Ownership of Data

The company responsible for your personal data is DuCIRCLE REWARDS, a company registered in the Kurdistan Region, Iraq) and can be contacted at [email protected].

Who do we share your personal information with?

We may disclose your personal information to any current or future member of the DuCIRCLE Programme group of companies, which might entail subsidiaries or holding companies.

We may disclose usage patterns and other analytics on aggregated data sets (these data sets aggregating your and other users’ information) to retailers and banks we work with.

We may disclose your personal information to third parties:

  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the Terms and/or other agreements.
  • To protect the rights, property, or safety of DuCIRCLE REWARDS, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • For certain purchases, offers, redeeming points, we may have to introduce you directly to that particular partner to facilitate the transaction. For this reason, the offer may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

The Legal Basis for Accessing and Processing your data

We rely on your consent for accessing and processing the mentioned categories of your data. Your grant us permission to process your data when you sign up via our app and specifically accept the processing of your data in order to provide you with our service.

We will only process your personal information where we have legal basis to do so. The legal basis depends on the reason or reasons DuCIRCLE collected or needs to use your information.

In almost all cases the legal basis will be:

  • To administer our contractual obligations to you as a member DuCIRCLE REWARDS
  • When it is in our legitimate interests to use your personal information to operate and improve our business
  • To comply with a legal obligation
  • To protect the vital interests of you or another person

Use of Cookies

We may obtain information about your general internet usage by using a cookie file which is stored on your mobile device. A cookie is a text-only string of data that is entered into the cookie file or ‘memory’ of the browser on your computer. It will typically contain the name of the domain from which the cookie has come, the ‘lifetime’ of the cookie, and a value, usually a randomly generated unique number. Cookies help us to improve the DuCIRCLE Programme to deliver a better and more personalised service. They enable us:

  • To estimate our audience size and usage pattern
  • To store information about your preferences, and so allow us to tailor our services according to your individual interests
  • To speed up your searches
  • To recognise you when you return to our services

All browser technologies enable you to manage the cookies in the cookie folder of your browser. This means that you can either delete cookies from your cookie folder once you have finished your visit at our services or you can set your preference with regard to the use of cookies before you begin surfing our website - for example you may be asked to re-enter some information - e.g. your name and password to use some pages.

Your rights and how to exercise it

Under the data protection laws of Iraq you have certain rights in relations to your personal information. In addition, we have given you a number of choices about how we collect and use it. For instance, you can decide not to receive marketing material from DuCIRCLE and object to some ways how we use your information. However, some of the decision or choices you make may impact our ability to provide you with points or rewards.

You can log into your account on the app to:

  • Access and update the contact details we hold about you
  • View your points statement and account transactions history
  • Opt-out of receiving marketing communication

If you wish to exercise any of your individual rights set out here in relations to your personal information you can:

  • Request access to your information if you cannot locate your details on the app
  • Ask that we update, complete or correct your information if you are unable to do so in the app
  • Ask that we erase or restrict our use of your information

When you are seeking access to your personal information or concerned about how we are using your information, please send us an email to [email protected].

Changes to this Privacy Policy

We may need to change our Privacy Policy from time to time when we add or further develop certain features or parts of our service to you.

We may also revise this Privacy Policy at any time for security, legal, best practice or regulatory reasons by amending this page.

If we make any changes to this Privacy Policy, we will let you know by publishing the updated version on our website.

You are required and expected to check these terms from time to time to take notice of any changes we have made, as they are binding on you.

Contact Us

If you wish to contact us in relation to this Privacy Policy or have any concerns, please contact our Data Protection Officer at [email protected].

Use of Cookies

We may obtain information about your general internet usage by using a cookie file which is stored on your mobile device. A cookie is a text-only string of data that is entered into the cookie file or ‘memory’ of the browser on your computer. It will typically contain the name of the domain from which the cookie has come, the ‘lifetime’ of the cookie, and a value, usually a randomly generated unique number. Cookies help us to improve the DuCIRCLE Programme to deliver a better and more personalised service. They enable us:

  • To estimate our audience size and usage pattern
  • To store information about your preferences, and so allow us to tailor our services according to your individual interests
  • To speed up your searches
  • To recognise you when you return to our services

All browser technologies enable you to manage the cookies in the cookie folder of your browser. This means that you can either delete cookies from your cookie folder once you have finished your visit at our services or you can set your preference with regard to the use of cookies before you begin surfing our website - for example you may be asked to re-enter some information - e.g. your name and password to use some pages.