1. Introduction

Shabaky ("we," "our," or "us"), operated by Liberty Gulf Management Solutions, is committed to protecting your personal data in accordance with the Personal Data Protection Law No. (30) of 2018 of the Kingdom of Bahrain ("PDPL").

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our digital enablement platform and services.

2. Data Controller

Liberty Gulf Management Solutions

Registered Address: Manama, Kingdom of Bahrain

Email: privacy@shabaky.com

Phone: +973 1700 0902

3. Personal Data We Collect

3.1 Information You Provide

Name and contact information (email, phone number)
Business information (company name, industry, services)
Payment information (processed securely through third-party payment processors)
Website content and preferences
Communication preferences and correspondence

3.2 Automatically Collected Information

Device and browser information
IP address and location data
Website usage data (pages visited, time spent, interactions)
Cookies and similar tracking technologies (with your consent)

4. Legal Basis for Processing

We process your personal data based on:

Consent: You have given explicit consent for processing your personal data for specific purposes
Contract Performance: Processing is necessary to fulfill our service agreement with you
Legal Obligation: We must process data to comply with Bahraini laws
Legitimate Interests: Processing is necessary for our legitimate business interests (e.g., fraud prevention, service improvement)

5. How We Use Your Personal Data

Create and maintain your website and digital presence
Process payments and manage subscriptions
Provide customer support and respond to inquiries
Send service updates, technical notices, and security alerts
Improve our platform and develop new features
Comply with legal obligations and prevent fraud
Send marketing communications (with your explicit consent)

6. Data Sharing and Disclosure

We do not sell your personal data. We may share your information with:

Service Providers: Third-party vendors who assist with hosting, payment processing, analytics, and customer support
Legal Authorities: When required by law or to protect our legal rights
Business Transfers: In connection with any merger, sale, or acquisition

7. International Data Transfers

In accordance with the PDPL, any transfer of your personal data outside the Kingdom of Bahrain requires:

Your explicit consent, or
Transfer to a country with adequate data protection laws recognized by the Personal Data Protection Authority, or
Implementation of appropriate safeguards (e.g., standard contractual clauses)

8. Your Rights Under PDPL

You have the following rights regarding your personal data:

Right to Access: Request a copy of your personal data we hold
Right to Rectification: Correct inaccurate or incomplete data
Right to Erasure: Request deletion of your personal data (subject to legal obligations)
Right to Restriction: Limit how we process your data
Right to Data Portability: Receive your data in a structured, machine-readable format
Right to Object: Object to processing based on legitimate interests
Right to Withdraw Consent: Withdraw consent at any time (without affecting prior processing)

To exercise your rights, contact us at privacy@shabaky.com. We will respond within ten (10) working days as required by the PDPL.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, secure servers, and regular security assessments.

10. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary based on the type of data and legal requirements.

11. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will take steps to delete it promptly.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated" date. Your continued use of our services after such changes constitutes acceptance of the updated policy.

13. Complaints and Regulatory Authority

If you have concerns about how we handle your personal data, please contact us first at privacy@shabaky.com.

You also have the right to lodge a complaint with the Personal Data Protection Authority (PDPA) of the Kingdom of Bahrain:

Personal Data Protection Authority

Website: www.pdp.gov.bh

Email: info@pdp.gov.bh

14. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or your personal data:

Email: privacy@shabaky.com

Phone: +973 1700 0902

Address: Liberty Gulf Management Solutions, Manama, Kingdom of Bahrain