Your privacy as a customer matters to us and we welcome you to the privacy policy (the “Policy”) of Mohamed Naser Al Sayer & Sons Est. Co. W.L.L. (MNSS) in relation to your use of the Roadside Assistance Web Application for Toyota & Lexus https://rsa.alsayergroup.com (the “Website”).

MNSS respects your privacy and will endeavor to protect your personal data. Any personal information you provide to us including and similar to your name, address, telephone number, location and e-mail address etc. will not be released, sold, or rented to any entities or individuals outside of our organization except as provided in the Policy.

The terms of the Policy that are set forth below are intended to inform you as to how we look after your personal data when you visit the Website (regardless of where you visit it from) and to explain to you what your privacy rights relating to that data comprise for these purposes. The expressions ‘you’, ‘your’ and ‘Customer’ or ‘customer’ are each intended to refer to you in such capacity.

For your information, we reserve absolutely the right at any time to amend the Policy’s terms from time to time by updating the “Privacy Policy” section of the Website. Any changes we make will be effective immediately, which will be notified to you by way of posting the updated Policy on the Website. You should check the Website from time to time to ensure that you are fully aware of any such amendments that we may make. Kindly also note that the terms of the Policy are subject in all respects to the Website’s Terms & Conditions, which in turn are subject to amendment from time to time in accordance with any terms and conditions that MNSS would like to apply. 

If your personal information changes at any time (such as post code, email address, for example), or if we have inaccurate information concerning you, we will endeavour to correct, update, or remove your personal data from our database in order to reflect the changes you have notified to us.

1. IMPORTANT INFORMATION AND WHO WE ARE  

1.1 THE PURPOSE OF THE POLICY  

The objective of the Policy is to provide you with information as to how MNSS collects and processes your personal data through your use of the Website, including any such data that you may provide when signing up for access of the Website. This Website requires access to your real-time location in order to function effectively. When you request assistance through this Website, we collect your location data to identify your exact position, assign the nearest available technician, and provide you the required services, as required and made available through this Website. This location tracking continues for the duration of the service request and is essential for ensuring timely and efficient support. By using the application, you explicitly consent to the collection and use of your location information for these purposes. Your data is shared only with authorized personnel and service partners directly involved in fulfilling your request and is not used for any unrelated purposes.

It is very important that you read the terms of the Policy together with any other privacy policy or fair dealing policy which we may subsequently provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using that data. The Policy supplements any other notices and privacy policies previously issued or posted by us and (unless otherwise stated) is not intended to override or replace any of them.

1.2 HOW TO CONTACT US

Should you have any questions concerning the Policy, its application, purpose or operation, including any requests by you to exercise your legal rights, please contact us using the contact number below or reach out to us by filling out the form available on the ‘Contact Us’ tab on the Website.

CONTACT NUMBER: 1803803/ 1830030

1.3 YOUR CONTACT DETAILS  

When contacting us, we may ask you for your contact information, including but not limited to your name, address, email address, civil id no. etc. so that we may respond and/or attend to your questions as attentively and as promptly as possible. Please be sure to have that information available at the material time. 

1.4 THIRD-PARTY LINKS  

The Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or otherwise enabling those connections may allow third - parties to collect or share personal data about you and your status or circumstances. We are not responsible for the content of any websites that are linked to the Website. We cannot and do not exercise any control over such third – parties or their websites or the operation of the applications concerned and thus we cannot be held responsible in any circumstances for the application or effectiveness of the privacy policies or statements contained therein.  Accordingly, we encourage you to read and note the terms of all such policies or statements as and when you visit any such third – party website, which may be materially different in terms of content and/or the protection of your personal data from that set forth in the Policy.

2. PERSONAL DATA

2.1 THE PERSONAL DATA WE MAY COLLECT ABOUT YOU, YOUR STATUS AND CIRCUMSTANCES  

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity of the person concerned has been removed or redacted so that his identity is not disclosed.

When a customer uses the Website, certain personal and operational data is collected, processed, and shared to deliver timely and effective assistance. This section describes the data handling process related to location tracking & communications.

By your accessing or use of the Website you agree that we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes family names, username or similar identifier, marital status, title, date of birth and gender, address, governorate, email address and telephone / mobile number.
• Vehicle or machine information (such as vehicle or machine registration number, model, model year, date of purchase or lease and service history)
• Contact Data which includes billing address, email address and telephone numbers.
• Financial Data which includes but is not limited to an individual’s financial status or transactions, transaction history, billing details, and/or any other data necessary for processing payments or verifying financial activitie
• Technical Data which includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website as well as the real-time Global Positioning System (GPS) coordinates of both the Customer’s vehicle and the assigned technician or other service personnel, as applicable.
• Profile Data which includes your username and password for access to the Website, requests or orders made by you, phone number, civil ID number, passwords, interests, preferences, feedback, and survey responses etc.
• Usage Data which includes information about how you use the Website and the goods and services available on it or through it.
• Marketing and Communications Data which includes your recorded preferences in receiving marketing materials and information from us and our third - parties (suppliers, repairers, and other service providers) and your recorded communication preferences.
• Any other data as may be required by us from time to time.
• Images such as those that you may submit for provision of any services by your use of the Website.
• Electronic signature confirming acceptance/completion of service to capture evidence of service delivery and ticket closure.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with the terms of the Policy.

It is important that the Personal Data we hold about you is kept accurate and current. Please keep us informed whenever your Personal Data changes in any respect during your relationship with us.

2.2 IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect Personal Data under the terms of any services through the Website, which we provide you with, and you fail to provide that data when requested, we may not be able to provide you such services.

2.3 HOW IS YOUR PERSONAL DATA COLLECTED?  

We use different methods to collect personal data from and about you including, without limitation:

Direct interaction with us. As our Customer, when you use our Website, we collect certain personal data such as your name, contact details, vehicle information, location and service request history. This information is used to verify your identity, coordinate service delivery, communicate with you during the assistance process (including through the portal and WhatsApp), and maintain service records. Your data is processed securely and only for purposes directly related to providing and improving the roadside assistance service. You may also provide us from time to time with details of your personal identity, contact information and financial data by means of filling in forms sent to you by us for completion or by corresponding with us by post, telephone, email or otherwise. These details may include personal data which you provide when you:

• instruct us to provide any services;
• subscribe to our service or publications;
• request marketing materials or information to be sent to you;
• provide us with feedback at our request or suggestion or when you contact us;
• complete and submit any customer enquiry or comment forms;
• make any sales inquiry or submit any contest or competition entry forms posted on the Website;
• ask us for information about a product or a service and related promotional or marketing events;
• request a vehicle or machine test drive and other incentive applications;
• make to, or receive from, us any telephone calls; these may be recorded by us in order to verify content and may be used together with your other records for regulatory compliance, quality control, and staff training, the prevention or detection of criminal activity and for attending to any customer complaint;
• participate in any surveys where personal data may be collected. If you enter any of our contests or competitions using your social media platforms (where available), we may collect information about you from your social media profile;
• agree that we may collect certain information about you or your machine or vehicle;
• interact with the Website, in which case we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies;
• Third parties or publicly available sources.

Technical Data which we may collect from the following parties and sources concerning you, your identity and other personal data:

(a)  analytics providers such as Google;

(b)  search information providers;

(c) regarding Contact, Financial and Transaction Data, from providers of technical, payment and delivery services; and

(d) regarding Identity and Contact Data, from publicly available sources.

2.4 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Any of the personal data which we collect from or in respect of you may be used by us for a range of purposes relating to the services that are offered on the Website. Those purposes include, without limitation:

• Where we need to perform any contract for goods and services which we are about to enter into, or which we have already entered into, with you.
• Where it is necessary for us to do so in relation to our Legitimate Interest (or those of a third party having an interest in any contract for the provision to you of goods and services, as referred to previously).
• Where we need to comply with a legal obligation binding upon us.
• Any other manner in which MNSS shall deem such usage appropriate provided that it shall be in conjunction with the applicable laws at all times.
• To personalize your experience of the offered goods, services and/or content as a customer (your information helps us to better respond to your individual needs);
• To enhance your experience as an actual or potential customer whenever you access the Website. We continually strive to improve our Website offerings based on information and feedback we receive from you;
• To improve the quality of our customer service (your Personal Data and the other information and feedback you provide to us helps us to more efficiently respond to your requests and customer service requests – such as receiving feedback, dealing with complaints, and providing customer support needs).

3. OPTING OUT  

You are entitled to request at any time that we or any third parties concerned to stop sending you marketing and promotion messages by logging into the Website and checking or unchecking relevant boxes in order to adjust your marketing preferences, or alternatively by following the opt-out links on any marketing message sent to you either by us or the third parties mentioned previously. Further you may submit such request to us by e – mail at any time.

Kindly note that your exercising your right to opt – out as described above will not affect or restrict the use of by us of personal data provided by you to us in relation to any product or services purchase, warranty registration, feedback regarding any product or services experience from the past or any other ongoing transactions entered into between you and us.

4. COOKIES

As you may be aware, cookies  are small text files, containing data about your general internet usage which are stored on the hard drive of your computer or mobile device. Cookies help us to improve the operation of the Website and to deliver a better and more personalized service to our customers. In particular, we use Google Analytics and similar products to enable us to track visitors to the Website.

You may disable or refuse cookies by way of setting your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may subsequently become inaccessible or may otherwise cease to function properly.

5. DISCLOSURE OF YOUR PERSONAL DATA

By your use of the Website, you agree that we may, without notice, share your personal data with any of the parties referred to below:  

• Service providers acting as processors who provide IT and system administration services to us;
• Our professional advisers acting as processors or joint controllers of the Website including lawyers, bankers, auditors, and insurers in the course of their providing consultancy, banking, legal, insurance and accounting services to us in the course of our business;
• Government regulators and other authorities acting as processors or joint controllers based in Kuwait who require reporting of processing activities in certain circumstances; or.
• Third - parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If any change occurs to the operation, management, nature or conduct of our business as a consequence of any such sale, transfer, or merger, then the successors in interest may use your personal data in the same way as set out in the Policy.

6. INTERNATIONAL TRANSFERS OF PERSONAL DATA 

Many of the third parties with whom we transact the business described on the Website may be located outside Kuwait. Consequently, where we transact with any of them for the provision of services requested by you, their processing of your Personal Data will necessarily involve a transfer of components of your Personal Data to jurisdictions outside this country.

In cases where personal data is transferred to a jurisdiction, MNSS will endeavor to implement reasonable safeguards to protect the data.

MNSS shall not be liable for any loss, misuse, or unauthorized access to personal data resulting from:
a. Transfers to third parties acting as independent controllers;
b. Compliance with legal obligations in the destination jurisdiction;
c. Circumstances beyond MNSS’s reasonable control, including actions or omissions of third parties.

Please contact us using the details provided in section 1.2 if you wish to receive further information regarding how, and the terms on which that transfer is made, and we shall use our best efforts to provide that information promptly.

7. PERSONAL DATA SECURITY AND STORAGE 

We have used all reasonable efforts to put in place appropriate security and other measures in order to ensure that no component of your personal data is accidentally lost or used or accessed in an unauthorized way, or otherwise altered or disclosed. In addition, we take all necessary steps in line with best international standards and practice in order to limit access to your personal data to those of our employees, agents, contractors and other third parties who have a business need to know. And you have our further assurance that all such persons (to the extent that the same is reasonably within our power and control)  will only process your personal data in accordance with our specific instructions and at all material times are subject to a duty of confidentiality binding upon, and enforceable against, them in accordance with applicable law and regulation.

The measures referred to above, for your further information, include procedures to deal with any suspected personal data disclosure breach and we will always use our best endeavors to notify you promptly of the occurrence of any such breach where we are legally permitted or authorized to do so.

Notwithstanding the preceding paragraphs, unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your personal data transmitted by you or on your behalf to the Website; any such transmission is at your own risk. Once we have received your personal data, we will use the strict procedures and security features described above to try to prevent unauthorised access.

8. PERSONAL DATA RETENTION

HOW LONG WILL WE RETAIN YOUR  PERSONAL DATA?  

We will only retain your personal data for as long as may reasonably prove to be necessary to fulfil the purposes for which we originally collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event that we receive a complaint from you regarding the services provided to you as a customer pursuant to the terms of the Website or if we otherwise reasonably believe it to be reasonably necessary to retain it in whole or in part for longer period.

When determining appropriate period for which we should retain your personal data, we shall take into account the quantity, nature and sensitivity of the personal data concerned, the original purposes for which we collected it  and whether we can achieve those purposes through other means, and all  applicable legal, regulatory, tax, accounting or other requirements.

9. YOUR LEGAL RIGHTS  

Under certain circumstances, you have the following rights:

• Access and correction
• Suspend access Website
• Withdraw consent
• Complaints: Any complaints that you may have regarding the implementation or operation of the Policy should submitted to us in the manner set forth in the Terms & Conditions contained on the Website.

10. NO FEE USUALLY REQUIRED FOR ACCESS TO YOUR PERSONAL DATA

You will not be required to pay any fee or other cost in order to access, change, or modify your Personal Data unless otherwise mutually agreed between you and us in any case where either a) the request is made in a justified emergency or b) we consider such request to be unnecessary or is being requested otherwise than on a routine basis or such requests are excessive or unjustified for the purpose they are made.

Requests for access, change or modification must be submitted via your registered email address. If you no longer have access to your registered email, you may submit a request through any other communication channel, which will be subject to additional verification requirements, including but not limited to identity verification. Your failure to comply with such verification requirements may result in the temporary or permanent suspension of your usage of the Website.

Notwithstanding the foregoing, any request to access, modify and/or change your Personal Data on the Website must be made by you personally and not by anyone else on your behalf.

11. WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you from time to time in order to help us confirm your identity and to ensure that your right to access your Personal Data (or to exercise any of your other rights) is being properly exercised. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request in order to expedite our response to that request.

12. TIME LIMIT TO RESPOND TO REQUESTS FOR ACCESS TO PERSONAL DATA  

We try to respond to all legitimate requests within a practically and reasonably possible duration, save where a request is made in a justified emergency, in which case we shall use our best endeavors to respond as quickly as is feasible. Occasionally our response could take us longer to respond to where your request is particularly complex, or you have made a number of requests within a short timeframe. In every case, we shall keep you updated as to the progress of our response.

13. CONTRACT

By accessing the Website, you authorize us to use your Personal Data for Legitimate Interest, and for the purpose of the Performance of Contract, if any.

For the purposes of the foregoing, the expression ‘Legitimate Interest’ means the interest of our business in enabling us to provide you with the highest possible quality of services and products and the best and most secure customer experience. The expression ‘Performance of Contract’ means our processing your Personal Data where it is necessary for the performance of any contract for goods and services into which you may enter with us or our taking any steps at your request before entering into such a contract, as may be applicable.

14. MISCELLANEOUS PROVISIONS

14.1 GOVERNING LAW

Your use of the Website shall be governed by the laws of Kuwait, without regard to conflict of law rules and any dispute between you and MNSS shall be resolved exclusively in the courts of Kuwait. This Policy has been drafted in accordance with the laws of the State of Kuwait applicable as of December 2024 and are subject to amendments in accordance with any changes in the applicable laws in the State of Kuwait.

14.2 LANGUAGE

This Policy is drafted in the English and Arabic languages. In the event of any discrepancy between the two languages regarding the interpretation of the Policy, the Arabic version shall accordingly prevail.

14.3 FAKE E – MAILS USING OUR NAME

We are aware of fake emails, popularly called "phishing" emails which can contain notices such as job advertisements, job offers and competition award notifications. These emails use our name to pretend they are genuine and exist solely for the purpose of obtaining private information about consumers (credit card numbers, bank account details or passwords, for example). These emails have no connection with us, and we do not use these methods for job advertising or for communicating with competition winners.

Unfortunately, these fake emails are a growing fraud on the internet. This practice is carried out either by sending bogus emails directly to a victim, or by directing them to a website where personal information is requested.

We advise that if you receive an email using our name that asks for personal details or financial information and you have concerns about its authenticity, then please treat such emails with extreme caution.