Privacy Policy

### 1. Who is responsible for your data

**Kuwait Business Centre / Adora Al Dhahabia Company** [PLACEHOLDER PH-15], licence 2024/1232, commercial registration 494277, trading as "Direct". To contact us about your data: [PLACEHOLDER PH-08: email address] or [PLACEHOLDER PH-06: phone number].

### 2. What we collect

1. **Account details:** your name, email address, phone number, and your password, stored **hashed** so that nobody can read it, including us. 2. **Billing details:** invoice type, and a company name and registration number if you choose a company invoice. 3. **Order records:** what you bought, the amount, the date, the payment status and a transaction reference from our payment provider. 4. **Viewing data:** which lessons you watched, your progress, and where you stopped, so we can resume you in the same place. 5. **Technical data:** your internet address (IP), browser and device type, and basic access logs, for security and to prevent abuse. 6. **Contact messages:** what you write on our Contact page, and your consent for us to use your details to reply. 7. **Your phone number for a service:** it is the number we call, so it is required when you buy a service.

**What we do not collect, and this part matters:**

- **We do not collect or store any identity documents through this website.** The website has no file upload, and no page asks you for a copy of your civil ID, your passport or a licence. - **We do not store payment card numbers.** Payment happens entirely on our payment provider's own page. - If your transaction needs documents, we collect them **outside the website**, through direct contact with our team, and they are used only to complete your transaction.

### 3. Why we collect it

1. To carry out your order, whether that is opening a course for you or calling you to start a service. 2. To send your receipt, account messages and password resets. 3. To prove your entitlement to watch what you bought. 4. To answer your questions and support you. 5. To protect the website from abuse and automated attacks. 6. To meet the accounting and legal requirements that apply in the State of Kuwait.

We do not use your data for third party advertising, and we do not sell it.

### 4. Payment

Payment happens on the page of our payment provider [PLACEHOLDER PH-19]. Your card details go straight to them and never pass through our systems. What we receive and keep is a transaction reference, the amount, the status and the method used. Our payment provider has its own privacy policy, which applies on their page.

### 5. Video and playback

Course videos are hosted with an **external video streaming provider** [PLACEHOLDER PH-30: streaming provider name], and are played through a temporary link issued to you after your entitlement is checked. The streaming provider processes technical playback data in order to deliver the video.

### 6. Who we share data with

We share only the minimum necessary, and only with these parties:

1. **Our payment provider** [PLACEHOLDER PH-19], to take payment and process any return. 2. **Our video streaming provider** [PLACEHOLDER PH-30], to play courses. 3. **Our email provider** [PLACEHOLDER PH-30], to send receipts and account messages. 4. **Our hosting provider** [PLACEHOLDER PH-30: provider name and server country], where the website's data is stored. 5. **Government bodies**, and only the data and documents needed to complete the transaction you asked us to carry out. 6. **Official authorities**, where we are required to do so by law.

Some of these providers may store data **outside Kuwait**. We choose established providers and we follow the requirements that apply in the State of Kuwait.

### 7. Cookies

We use as few as possible:

1. **Necessary cookies** for signing in, keeping your cart and remembering your language. 2. **We do not use advertising cookies or third party tracking today.** If we add any measurement tools later, we will update this page first.

### 8. How long we keep it

1. Account details: for as long as your account exists. 2. Order records and receipts: [PLACEHOLDER PH-29: period], in line with accounting and legal requirements. Order records are not deleted, because they are a financial document. 3. Contact messages: [PLACEHOLDER PH-29: period]. 4. Technical logs: [PLACEHOLDER PH-29: period].

### 9. Your rights

1. Ask for a copy of the data we hold about you. 2. Correct anything that is wrong. Most of it you can edit yourself in your profile. 3. Ask us to delete your account. Note that deletion means losing access to courses you bought, and that order records stay stored as a financial document. 4. Withdraw your consent to marketing messages at any time. 5. Raise a question or a complaint by contacting us at [PLACEHOLDER PH-08].

We reply to your request within [PLACEHOLDER PH-16: reply time].

### 10. Data security

The website runs over an encrypted connection, passwords are stored hashed and cannot be recovered, and access to data inside our team is limited to the people who need it for their work. **We store no card numbers and no identity documents on the website.** Even so, no system is completely secure. If an incident affects your data we will deal with it and notify whoever must be notified.

### 11. Children

The website is not intended for children and we do not knowingly collect their data.

### 12. Changes to this policy

We may update this policy. Each update is issued as a version with a new effective date, and the last updated date is shown at the top of the page.

### 13. Language

If the Arabic and English versions differ in meaning, **the Arabic text prevails**. [PLACEHOLDER PH-18]