Lapis Communications

Privacy Policy

Effective: September 2023

1. Introduction

The Quqnoos Group of Companies (“Quqnoos Group”) have diverse interests but are substantially involved in three main areas: Technology, Logistics, and Media.  The Quqnoos Group has operations in the UK, UAE, Jordan, Turkey and Afghanistan. 

The holding company of the Quqnoos Group is based in the UK, Quqnoos Limited, a company organized and existing under the laws of England and Wales (Registered Number 13104416) and having a registered office at Sovereign House, Port Causeway, Wirral, Merseyside, CH62 4TP (“QL”). Below, QL there are three main operational silos, as follows:

QUQNOOS INVESTMENT LIMITED

The main operational hub for Quqnoos Group where senior administrative level staff sit across the whole of Quqnoos Group, located in Dubai International Financial Centre, Dubai, UAE (“DIFC”). QIL is 100% owned by QL.

MOBY GROUP HOLDINGS LIMITED

MOBY is the main media company within the Quqnoos Group. MOBY is the holding company of the Quqnoos Group’s media operations in the UAE, UK, Turkey and Afghanistan. MOBY is wholly owned by QL.

LAPIS INTERNATIONAL HOLDINGS LIMITED

LAPIS provides strategic counsel to a variety of clients ranging from national governments and international institutions to non-profit organizations and private sector businesses. LAPIS is wholly owned by QL.

Quqnoos Group (collectively “Quqnoos”, “we” or “us”) collects information about you when you use or access our websites and other web-based products, information or services (collectively, the “Online Services”) and through other interactions and communications you have with us. This privacy policy sets out the basis on which any information, including any personal data, we collect from you, or you provide to us, will be processed by Quqnoos. Each time you access or use the Online Services or provide us with information, by doing so you are accepting and consenting to the practices described in this privacy policy.

2. Scope and Application

This privacy policy (this “Privacy Policy”) applies to persons anywhere in the world who access or use our Online Services (“Users”).

3. Collection of Information

Information We Collect Through Your Use of the Quqnoos Websites

When you use any Quqnoos Online Services, we may collect personal information (i.e. information that could be used to contact you directly such as full name, postal address, phone number, credit/debit card information, or email address; “Personal Information”) and demographic information (i.e. information that you submit, or that we collect, that is not personal information; this may include, but is not limited to, post code, hometown, gender, username, device information, including the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, device location, IP address, SMS data, transaction information, age/birth date, browsing history information, searching history information, and registration history information) (“Demographic Information” and, together with Personal Information, “Personal Data”).

Information You Provide to Us

We collect information you provide directly to us through your access or use the Online Services or otherwise communicate with us. This information may include: your name, email address, phone number, postal address, profile picture, payment method, financial and credit card information, and other information you choose to provide.

Please note that we do not knowingly collect, keep or maintain Personal Data or Information from children under the age of 18 through the Online Services, as we require that all users represent to us that they are at least 18 years old.

4. Use of Personal Data

We may use Personal Data which you provide to us or we collect from you to:

  • Fulfill contractual obligations to you or your legal organization / company;
  • Provide, maintain, and improve our Online Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Users, authenticate users, and send administrative messages;
  • Perform internal administration and operations, including, for example, to prevent fraud and abuse of our Online Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
  • Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of Quqnoos and other companies, where permissible and according to local applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards;
  • Notify you about changes to our Online Services;
  • Allow you to participate in any interactive features of our Online Services;
  • Keep our Online Services safe and secure; and
  • Personalize and improve the Online Services, to provide or recommend features, content, social connections, referrals, and advertisements.

5. Storage and Transfer of Personal Data

By submitting your Personal Data, you acknowledge that for lawful, legitimate purposes, we may transfer the Personal Data described in this privacy policy to and from, and process and store it in, the United Arab Emirates and other countries, some of which may have less protective data protection laws than the region in which you reside. Where this is the case, we will take appropriate technical and organisational measures to protect your Personal Data in accordance with this privacy policy.

To preserve the integrity of our databases, to carry out on-going Online Services on your behalf, for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations, we retain Personal Information and Demographic Information submitted by Users for a reasonable length of time.

Quqnoos is not responsible for the accuracy of the information you provide and will modify or update your Personal Data in our databases upon your request.  If required by law or at your request, we will update, restrict the use of, erase or archive your Personal Data. By accessing or using the Online Services, you do hereby represent and warrant that you understand that all information submitted by you through the Online Services or otherwise to Quqnoos may be used by Quqnoos in accordance with applicable laws and this privacy policy.

6. Sharing of Personal Data

We may share Personal Data which we collect about you as described in this privacy policy or as described at the time of collection or sharing, including as follows:

Through Our Online Services

We may share your Personal Data:

  • With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us; and
  • With third parties with whom you choose to let us share your Personal Data, for example other apps or websites that integrate with our API or Online Services, or those with an API or Service with which we integrate;

Other Types of Sharing

We may share your Personal Data:

  • With Quqnoos subsidiaries and affiliated entities;
  • With vendors, consultants, marketing and advertising partners, and other service providers who need access to such Personal Data to carry out work on our behalf or to perform any contract we enter into with them;
  • In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
  • With law enforcement officials, government authorities, or other third parties as required by law;
  • With third parties in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
  • If we otherwise notify you and you consent to the sharing; or
  • With third parties in an aggregated and/or anonymized form which cannot reasonably be used to identify you.

7. Your Choices

Marketing, Opting In and Opting Out

When you provide your Personal Data to us, we acknowledge that you are opting in to our processing it for legitimate purposes, and where applicable, for specific purposes as agreed between you and us or as per your understanding at the time the Personal Data is collected from you. Quqnoos provides Users the opportunity to opt-out of receiving communications from us and our subsidiaries at any time.

You have the option to ask us not to process your Personal Data for marketing purposes and to remove it from our database, to not receive future communications or to no longer receive our Online Services.

Access to Information

You have the right to access information held about you. Your right of access can be exercised in accordance with the Acts. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.

Changes to this Privacy Policy

We may change this privacy policy from time to time. If we make significant changes in the way we treat your Personal Data, or to the privacy policy, we will provide you notice through the Online Services or by some other means, such as email. Your continued use of the Online Services after such notice constitutes your consent to the changes. We encourage you to periodically review this privacy policy for the latest information on our privacy practice.

8. Security Precautions

Quqnoos makes every effort to ensure that your Personal Data is secure on its system. Quqnoos has staff dedicated to maintaining our privacy policy as set forth herein and other privacy initiatives, periodically reviewing Web security and making sure that every Quqnoos employee is aware of our security practices. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Quqnoos cannot guarantee the security of any Personal Data you transmit to us, and you do so at your own risk. If You have any further questions on this issue, refer to our customer terms of use. To the extent permitted by applicable law, Quqnoos expressly disclaims any liability that may arise should any other individuals obtain the Personal Data you submit.

9. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website and the Online Services we provide. By accessing and browsing our website, you are agreeing to our use of necessary cookies, and may select what other cookies to collect that may enhance your user experience or provide information to third parties for advertising purposes.

10. Contact Us

If you have any questions, comments and requests related to this Privacy Statement, or if you have any complaints related to how Quqnoos processes your personal data, please contact us at:

Legal Department
Moby Media FZ-LLC
PO Box 478802
Office 408, 4th Floor, Bldg. 3
Studio City, Dubai, UAE

Or at [email protected]