Privacy Policy

This Privacy Policy (“Privacy Policy”) aims to detail how our company, MASFOOFAT SHAHEEN COMMUNICATION EQUIPMENT SOFTWARE DESIGN L.L.C (the “Company”, “We”), collects and processes the following types of information:

(a) Information about the Company’s customers: Personal information collected and processed by the Company for its business customers (the “Customers”), including personal information that Customers input into the Company’s e-Desk Travel platform for managing tourism offices and travel agencies (the “Platform”) while using the Company’s services, including the Website and the Platform (the “Services”).

(b) Information about users: Personal information related to representatives of the Customers (“Users”), including account details, system access information, and financial details for billing purposes.

(c) Information about Potential Customers: Personal information concerning visitors to our website, https://www.edesk.travel/ (the “Website”), and any other potential customer (the “Potential Customer”) who interacts with us via the Website, advertisements, content, email communication, or any other means.

If you are a Customer, User, or Potential Customer using the Platform and/or the Website, please read this Privacy Policy carefully. There is no legal obligation for you to provide the Company with your personal information, and you may choose to do so (or refrain from doing so) voluntarily. If you do not wish to provide personal information to the Company or for your personal information to be processed by the Company or any of its suppliers, you are requested not to use the Services.
This Policy is an integral part of the Website’s Terms of Use and the Platform’s Terms of Service. Any use or attempt to use the Website, Platform, and the Company’s Services constitutes agreement to this Privacy Policy, including the collection and processing of personal information as described below. To withdraw your consent, please contact us at: [email protected]

1. Collection and Disclosure of Personal Information

The term “Personal Information” in this Privacy Policy refers to any data that directly or indirectly identifies an individual, such as full name, ID number, email address, phone number, payment methods, company affiliation, physical address, and/or other personal information. The term Personal Information does not include aggregate or anonymous information that does not reasonably identify a natural person, such as browsing patterns and usage of the Website and the Platform. The Company collects the following types of information in connection with the services offered:

(a) Identifiable Information Provided Voluntarily by Customers, Users, and Potential Customers:

Name, email address, phone number, job title, workplace, passport details, identification photo, access passwords, payment methods, inquiry content, and any other personal information provided by Users and/or in our possession during registration or login to the Platform, when creating a customer account, and/or when updating a customer account. This personal information is collected from you directly or from other sources and third parties, such as the Company’s Customers.

(b) Identifiable Information Provided During Communication with Customers, Users, and Potential Customers:

Personal Information included in any form you may complete and submit to us, including for support requests for the Services, surveys, feedback, recommendations; audiovisual information provided during visual meetings; correspondence, screenshots, documents, and related information that may be automatically collected for purposes such as analysis, quality control, product improvement, training, and document retention.

(c) Automatically Collected Information:

The Company may collect and utilize third-party services to collect and analyze anonymous, statistical, or aggregate information related to the use of the Services, including: connection information to the Platform and the Website; technical information about usage patterns of the Services such as IP address and approximate geographical location derived from the IP address, information about the hardware and software used to connect to the Services (device type, operating system, device or application identifier, browser version, location data); system logs and event records related to those IP addresses and devices, including for technical support purposes; cookies information installed on your device from which you access the Website and/or the Platform.

The Company collects and/or generates this information automatically, including through the use of data analytics services and tracking tools (such as cookies) that provide information about a Potential Customer’s visit to the Website, web pages visited on the Website, times of visit, advertisement or email from which they navigated to the Website, usage patterns on the Platform and its features, and technical information about the Platform’s performance and stability.

2. The Company as a Holder of Personal Information

With regard to Personal Information inputted into the Platform by the Company’s Customers about their customers, the Company will be a [“Processor”][“Controller”] of personal information as defined by the Privacy Law.[Obayda: this should be reviewed by Tarek to confirm or adjust terms and language under UAE law] The Company processes this personal information on behalf of its Customers and subject to their instructions.

As stated in the Terms of Use, the Company’s Customers bear sole responsibility for determining the use of the Platform and for informing their customers and obtaining their explicit consent to input personal information about them and its processing by the Company. It is the Customer’s responsibility to comply with the legal requirements related to the collection, use, and processing of personal information via the Platform, including responding to requests for access to personal information.

3. Use of Personal Information

The Company uses personal information in accordance with this Privacy Policy and applicable law for the following purposes:

a. To enable the use of the Services, including the Platform.
b. To provide technical support, including by examining and monitoring the Services, as well as for diagnosing and fixing issues through remote access.
c. To issue invoices and process payments.
d. To allow you to customize the Services to your specific needs.
e. To identify you and save you the need to re-enter your details upon repeat logins to areas requiring registration.
f. To improve and enhance the Services, including the Platform.
g. To optimize our marketing and sales systems, including enhancing our advertising means based on browsing and usage patterns on the Platform.
h. To contact you and send you from time to time information related to the Services, including the Platform.
i. To improve the Company's information security measures, including for preventing and managing fraud or unauthorized activity risks.
j. To enforce the Terms of Use of the Website and/or the Terms of Service of the Platform, comply with legal requirements, and assist authorized authorities and any third party when the Company deems necessary.
k. For any other purpose detailed in this Privacy Policy or the Terms of Service of the Platform and/or the Terms of Use of the Website.

4. Storage and Retention of Personal Information

The Personal Information collected by the Company is stored and retained with its suppliers on servers in Israel and the United States as reasonably required to provide the Services and subject to applicable law. Your consent to this Policy also constitutes consent to storing information abroad and transferring it to the above countries.

Personal information will be retained as long as reasonably necessary to provide the Services; to comply with our legal and contractual obligations; or to defend against an existing or future dispute, subject to the Company’s discretion. The period during which the information will be retained after the termination of your engagement with the Company will be determined based on the nature and sensitivity of the information, the purposes for which it was collected, and relevant legal requirements.

5. Disclosure of Information to Third Parties

The Company will not transfer the personal information you provide to third parties except in the following cases:

a. Proper provision of the Company’s Services: The Company may share personal information with selected service providers (the “Service Providers”) as part of providing the Services, including cloud storage providers, information security, billing and payment processing, data analysis, direct mailing, advertising, and legal or financial consulting. These Service Providers may have access to Personal Information we collect, subject to the data processing agreements concluded with them.

b. Interfaces with third-party services: Customers and Users may interface, via the Platform, with third-party services (e.g., payment processing services, passport scanning services), provided such an interface is supported by the Platform. These service providers may receive certain Personal Information about you, depending on the nature of the interface. If you do not wish for your personal information to be shared in this way, please contact the Customer who input your details into the Platform. For the avoidance of doubt, these third-party services, and any information you process, input, or transmit to them, are subject to their terms of use and privacy policies, not this Privacy Policy.

c. Fraud prevention: In case of actions that the Company deems to violate the law or the Terms of Service of the Platform, or attempts to perform such actions using the Services.

d. Binding order: In case the Company is required, by a court order or the request of an authorized authority, to provide personal information about you, subject to applicable law.

e. Legal dispute: In any dispute, claim, demand, or legal proceedings between you and the Company and/or anyone on its behalf.

f. Protection of you or a third party: When the Company deems the disclosure of information necessary to prevent serious harm to your rights, body, or property or those of a third party.

g. Mergers and acquisitions: If the Company transfers its activity/assets or any part thereof to a third party, the Company may transfer a copy of the personal information collected about you to the acquiring entity, provided the acquiring entity assumes similar obligations toward you as those outlined in this Policy.

h. Your explicit request: For the avoidance of doubt, the Company may share Personal Information about you in additional ways and circumstances, subject to your explicit consent, legal requirement, or data anonymization.

6. Cookies and Tracking Technologies

Some of the Services utilize “cookies” and similar technologies to assist the Company in providing the Services regularly, collecting statistical data about their use, for information security purposes, to enhance the user experience, and more. “Cookies” are text files created by the browser that may contain various information about your usage patterns of the Services, including personal information such as IP address. You can avoid the collection of cookies and/or delete existing cookies through your browser settings, which vary depending on the browser. For this purpose, please refer to your browser’s help file.

Most browsers also allow managing the settings for using cookies. It is important to note that disabling cookies may impair your ability to use some of the features of the Services, as well as the quality of their functioning.

The Company utilizes third-party analytics tools to analyze and improve the Services and their customization. These tools collect information about your interaction with the Services, including through the use of cookies and similar technologies, as per their privacy policies. The Company is not responsible for any use made by this third party and/or any other party not under its full control,

7. Direct Communication

The Company may contact you via email, phone, SMS messages, and notifications on the platform.

Operational Notifications: The Company may contact you regarding important information related to the Services. For example, we may send you notifications about changes or updates to the Services, billing issues, system access attempts, password resets, and more.

Marketing Notifications: We may inform you about new features, additional value propositions, events, special opportunities, and/or any other information that we believe may be of value to you as a Customer, User, or Potential Customer. We may send these notifications through any communication means available to us, via the Services or through a marketing campaign on other websites. At any time, you may withdraw your consent to receive such information and stop receiving it by sending a written request to the Company.

8. Your Rights and Options

The following rights may apply to you based on the applicable law:

a. Right of access: You are entitled to access your Personal Information processed by the Company.

b. Right to rectify: You may request rectification or completion of Personal Information that is incorrect, outdated, or incomplete.

c. Right to delete: You may request the deletion of Personal Information if it is no longer necessary for the purposes for which it was collected, if you withdraw your consent, or if there is no other legal basis for its processing.

d. Right to restrict processing: You may request the restriction of processing in specific circumstances, such as when the accuracy of the Personal Information is contested.

e. Right to object: You have the right to object to the processing of your Personal Information for specific purposes.

f. Rights of the Data Subject: You have the right to receive the Personal Information that you provided to the Company in a structured, commonly used, and machine-readable format and to transmit such data to another controller, where technically feasible.

To exercise your rights, please contact us at [email protected]. Your request should include the necessary details to identify your account or the specific information in question, along with any supporting documentation. The Company will process your request in accordance with applicable law

9. Information Security

The Company takes reasonable measures to safeguard the Personal Information it processes. These measures include administrative, technical, and physical security controls designed to prevent unauthorized access, use, disclosure, or loss of Personal Information. However, no system is completely impervious to breaches. Therefore, the Company cannot guarantee the absolute security of its databases, nor can it ensure that the information you transmit over the Internet will not be intercepted.

10. Governing Law and Jurisdiction

This Policy shall be interpreted in accordance with the laws of the United Arab Emirates [TBC with Tarek], and only such laws shall apply. By consenting to the use of the Services and/or the Platform, you agree that the exclusive jurisdiction for any claim, dispute, or legal action arising out of or in connection with this Policy shall be vested solely in the competent courts in ___________.[Obayda: this should be reviewed by Tarek to confirm or adjust the language if we will opt to UAE law]

11. Amendments to the Privacy Policy

The Company may update this Privacy Policy from time to time to reflect changes in its practices, legal requirements, or for any other reason. The latest version of the Policy will be posted on the Website and the Platform. In the event of material amendments, the Company may provide a more prominent notice or seek your consent, where required by law. Your continued use of the Services after publication of any amended Privacy Policy constitutes your agreement to the updated terms.

For any questions or concerns regarding this Privacy Policy, please contact us at [email protected]

12. Effective Date

This Privacy Policy was last updated on March __ 2025. It becomes effective from the date of publication on the Website and the Platform.