Privacy Policy

IVT COMMUNICATIONS FZC LLC (“IVT”, “Company”, “we”) is a company incorporated under the laws of the UAE and committed to compliance with applicable data protection laws.

Afina Data Monetization Platform (“Afina”, “Afina Platform”) is a software product developed by IVT. Afina is deployed exclusively within the infrastructure of Mobile Network Operators (“MNOs”). MNOs act as controllers of personal data processed within Afina. IVT may act as a processor only when providing technical support, bug fixing, or model tuning for Afina upon explicit request of an MNO.

This Privacy Policy applies to the processing of personal data carried out by IVT in connection with:

• The operation of our corporate website www.afinadmp.com (the “Website”), where IVT acts as a data controller; and
• Limited processing of personal data within Afina, where IVT may act as a data processor on behalf of an MNO when authorized.

By visiting this Website and requesting information, products, or services, you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not provide any information, or use any of the services or products offered or provided on this Website.

Please note: This Privacy Policy changes from time to time and changes are effective upon posting. Please check back frequently for updates as it is your sole responsibility to be aware of changes. We do not provide notices of changes in any manner other than by posting the changes at this Website.

This Privacy Policy describes the information collection, use, and disclosure practices of IVT with respect to:
(a) the Website, including all related divisions, subsidiaries, and affiliated companies (collectively, the “Websites”); and
(b) the engagement of third-party service providers acting on behalf of IVT.

Information collection and use

Personal data provided via the Website (e.g., contact forms, partnership requests, job applications) is processed by IVT as a controller to operate the Website and respond to you.

Personal data within Afina is controlled by the MNO; IVT may access it solely as a processor under the MNO’s instructions for defined support purposes.

In this Privacy Policy, “personal data” means any information relating to you as an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

For the avoidance of doubt, personal data does not include information from which you cannot be identified (which is referred to simply as data, non-personal data, anonymous data, or de-identified data).

In this Privacy Policy, “processing” means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

IVT does not knowingly collect personal data of children under the age applicable in their jurisdiction (e.g., 16 in the EU; 13 under COPPA in the US). If we learn that we hold such data, we will promptly delete it from active systems and securely delete or anonymize backups within a reasonable timeframe. Parents and guardians are encouraged to monitor children’s online activities.

How do we collect personal data and for what purposes

A. Website (IVT as controller)

Scenarios of processing:

1. Provision of requested services or information — respond to inquiries, provide materials, set up demos. Categories: Identity, Contact, Technical Data.
2. Communication and partnerships — manage business communications. Categories: Identity, Contact, Financial Data (invoicing).
3. Recruitment — evaluate candidates. Categories: Identity, Contact, employment-related data.
4. Marketing communications (opt-in only) — send newsletters, product updates, invitations. Categories: Identity, Contact, Marketing and Communications Data.
5. Website administration and security — ensure functioning, prevent fraud and bot abuse, improve performance. Categories: Technical Data (IP, browser, cookies, logs, anti-bot tokens).
6. Compliance and legal obligations — KYC/AML/CFT, regulator response. Categories: Identity, Contact, Financial, Technical Data.

B. Afina Platform (MNO as controller; IVT may act as processor under MNO instructions)

• Categories of data (determined by the MNO): Subscriber Identity Data, Traffic Data, Service Usage Data, Technical Data (device identifiers, network logs, geolocation where applicable).
• Purpose (defined by the MNO): provision of telecom services, customer analytics, targeted advertising, fraud detection.

Important: IVT does not determine the purposes of such processing. IVT may access personal data only as a Processor, and only under documented instructions of the MNO.

Legal Basis for Processing

• For Website-related processing: consent (e.g., opt-in marketing or non-strictly-necessary cookies); necessity for performance of a contract; legitimate interests of IVT (including operating the Website securely, protecting it from spam and automated abuse, and measuring the effectiveness of our LinkedIn advertising after consent); or legal obligations.
• For Afina-related processing: legal basis is determined by the respective MNO, and IVT acts only under documented instructions of the MNO.

By submitting your information through the Website, you agree to the processing described in this Privacy Policy. Personal data will be retained for as long as your relationship with IVT is active. Once the relationship ends, data is stored only as necessary to comply with legal obligations or to defend legitimate interests, unless you exercise your right to erasure.

Confidentiality and security

IVT implements commercially reasonable technical and organizational safeguards, including encryption, secure servers, and access controls, in accordance with data protection legislation.

Cookies and tracking

We use cookies and similar tracking technologies to operate the Website, analyze usage, improve user experience, and protect the Website from spam and automated abuse.

Categories of cookies used on the Website:

1. Strictly necessary cookies — enable core Website functionality (security settings, session management, load balancing, user authentication). Legal basis: strictly necessary for the provision of the Website; do not require consent.
2. Functional cookies — store your preferences (e.g., language settings, personalization). Legal basis: explicit consent collected through the cookie banner.
3. Analytical and performance cookies — collect aggregated information on Website usage (e.g., Google Analytics). Legal basis: explicit consent collected through the cookie banner.
4. Marketing cookies and ClickID tracking — track interactions when you click on links or offers. ClickID measures conversion and attributes traffic to campaigns. We use the LinkedIn Insight Tag (cookies including li_sugr, lidc, bcookie, bscookie, UserMatchHistory, AnalyticsSyncHistory) for measurement of LinkedIn advertising. Legal basis: explicit consent in the Marketing category of the cookie banner.
5. Bot protection / Google reCAPTCHA — the Website uses Google reCAPTCHA on contact and partnership forms to prevent automated abuse. reCAPTCHA may set its own cookies and transmit visitor IP and interaction signals to Google LLC for analysis. Legal basis: legitimate interest under Art. 6(1)(f) GDPR (anti-spam / fraud prevention); loaded as strictly necessary.

Cookie management and consent

• You can control or disable cookies at any time through your browser or device settings.
• Consent for optional cookies (functional, analytical, marketing) is collected via the cookie banner on our Website. You may accept or reject these categories separately.
• You may change your cookie settings at any time via the Cookie Settings link or by clearing cookies in your browser.
• More detailed information about the specific cookies we use (including their names, providers, and retention periods) is available in our separate Cookie Notice.

Third parties access

Your personal data may be transferred to third parties where necessary to comply with legal obligations or in order to provide the services for which such third parties are engaged, or in order to support the operation and security of the Website and Afina.

IVT engages third-party service providers under written Data Processing Agreements (DPAs) imposing obligations no less protective than those in applicable data protection laws. Where personal data is transferred outside the EEA, transfers are carried out either on the basis of an adequacy decision adopted by the European Commission or, in the absence thereof, subject to appropriate safeguards such as Standard Contractual Clauses (SCCs). These providers include:

• SendPulse — email marketing and communication services.
• WordPress — website hosting and content management system (CMS).
• Unisender — mailing list management and email campaigns.
• Zapier — workflow automation and service integrations.
• Notion — collaboration and knowledge management platform.
• Digital Ocean — cloud infrastructure and hosting services (servers may be located outside the EEA).
• LinkedIn Ireland Unlimited Company (controller for visitors in the EEA, UK and Switzerland) / LinkedIn Corporation (controller for visitors elsewhere) — receive Insight Tag signals when a visitor consents to Marketing cookies. Purpose: measurement of LinkedIn advertising effectiveness, audience-building, and conversion tracking. Personal data: hashed identifiers, IP address, page URL, user agent.
• Google LLC — provides multiple services to IVT: (a) Google reCAPTCHA on Website forms (receives request metadata including IP, user agent, and interaction signals); (b) Google Fonts CDN serving Web Fonts (fonts.googleapis.com / fonts.gstatic.com); (c) Google Workspace, used as IVT corporate email and productivity infrastructure for inbound and outbound communications (e.g., privacy@afinadmp.com, sales@afinadmp.com, legal@afinadmp.com).
• cdnjs.cloudflare.com — passive content delivery network for open-source JavaScript libraries (e.g., jQuery). No personal data is transmitted beyond standard request metadata; no DPA is required because no personal data is processed on our behalf by this CDN.
• Contractors providing technical support services on behalf of IVT.

Each of the above providers (other than the passive CDN) has entered into a Data Processing Agreement (DPA) with IVT, ensuring that personal data is processed only as instructed by IVT and in accordance with the GDPR, UK GDPR, FADP, and LGPD where relevant.

Your rights as a data subject

You have rights under applicable data protection laws (GDPR, UK GDPR, FADP, LGPD, UAE PDPL, PDPA, POPIA, and others) including: information and transparency; access (Art. 15 GDPR); rectification (Art. 16); erasure (Art. 17); restriction of processing (Art. 18); object (Art. 21); data portability (Art. 20); withdraw consent; and not be subject to solely automated decision-making (Art. 22).

To exercise your rights, contact: privacy@afinadmp.com. You have the right to lodge a complaint with a competent data protection authority.

International application of data protection laws

This Privacy Policy is intended to comply with the EU GDPR and other applicable laws including UAE PDPL, LGPD (Brazil), UK GDPR, FADP (Switzerland), PDPA (Thailand), POPIA (South Africa), CIS data protection laws, and Asia-Pacific data protection laws.

Where personal data is transferred outside the EEA, the UK, or Switzerland, IVT relies either on adequacy decisions or on appropriate safeguards such as SCCs or other lawful transfer mechanisms.

Contacting us

• privacy@afinadmp.com — for all inquiries related to data privacy, including exercising your data subject rights under GDPR, UK GDPR, FADP, LGPD, UAE PDPL, PDPA, or POPIA.
• sales@afinadmp.com — for commercial inquiries, partnerships, or business-related communication.

This Website is owned and operated by IVT COMMUNICATIONS FZC LLC, a company incorporated and operating under the laws of the United Arab Emirates, located at: BLA-SP1-97, AMC - Boulevard - A Building, Ajman Media City. Registered number: 3621.