Welcome to the Win Sustainably’ privacy policy.
Win Sustainably is Win Sustainably Portal LLC, a limited company incorporated in the Emirate of Dubai, United Arab Emirates with professional license number 1079662, and with its registered office address at professional license number 1156334 and with its registered office address at Office OFF3-058, Mohammed Saeed Harb Building, Port Saeed, Bur Dubai, PO Box 44320, Dubai, United Arab Emirates (“Win Sustainably”, "QA'LIL", “us”, “we”, “our”). and we operate this website and manage and operate the mobile application called WIN Sustainably and the related web-based portal (“Platform”) in the United Arab Emirates (“UAE”).
The Platform enables Customers who are registered on the Platform to make an order (an “Order”) for surplus food items packaged into boxes (each a “WIN Box”) listed on the Platform from businesses who have registered with us on the Platform (the "Food Businesses") for pick-up or delivery.
In this privacy policy, references to “you” or “your” are references to Food Businesses, customers and visitors to this site.


Purpose of this privacy policy
This privacy policy aims to give you information on how Win Sustainably collects and processes your personal data through your use of the Platform, including any data you may provide when you register and conduct transactions on the Platform or when you sign up to our newsletter.
The Platform is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may 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 your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Win Sustainably is the controller of and is responsible for your personal data ("Controller").
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. We will update the date at the top of the Privacy Policy when any changes are made.  The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Platform
It is important that the personal data we process about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
The Platform may include links to third-party websites, plug-ins and applications including but not limited to websites relating to events which we are organising and websites and applications which provide ticket ordering services. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data your first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data billing address, delivery address, email address and telephone numbers.
• Dietary Information your dietary requirements and food allergies
• Financial Data bank account and payment card details
• Transaction Data details about payments to and from you and other details of products and services you have purchased.
• Device Data 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,
• Technical Data 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 our application and website.
• Content Data information stored on your Device, including [friends' lists,] [login information,] [photos, videos or other digital content,] [check-ins,]
• Profile Data your username and password, in-App purchase history, your interests, preferences, feedback and survey responses
• Usage Data includes information about how you use our application and website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data your current location
Aggregated Data
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 but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 this privacy policy.
Sensitive Personal Data
Other than dietary information, we do not collect on the site any Sensitive Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect on the site any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.


We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact, Dietary, Financial, Transactions and Marketing and Communications Data by filling in forms through the Platform, signing in through your social media accounts  or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account;
• make a purchase on the Application
• subscribe to our service or publications;
• consent for marketing to be sent to you;
• enter a competition, promotion or survey;
• interact with us via our social media platforms;
• enter into an agreement with us; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Device, Technical, Content and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Location Data. We also use [GPS technology OR [OTHER TECHNOLOGY]] to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by [disabling Location Data in your settings.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Device and Technical Data from the following parties:
(a) analytics providers (such as Google and Firebase);
(b) advertising networks; and
(c) search information providers
(d) third party partners
• Identity, Contact, Financial and Transaction Data from providers of technical, ticketing, payment and delivery services.
• Identity, Contact, Financial and Transaction Data from our business partners.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources.

We use cookies [and/or other tracking technologies] to distinguish you from other users of the Platform and to remember your preferences. This helps us to provide you with a good experience when you use the Platform and also allows us to improve the Platform. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where you have consented to the processing of your personal data.
• Where we need to perform the contract, we are about to enter into or have entered into with you.
• To protect your interests.
• Where we need to comply with a legal obligation.
• To initiate or defend against any actions to claim rights or legal proceedings, or related to judicial or security procedures.
We will get your consent before sending you third party direct marketing communications via email or text. You have the right to withdraw consent to marketing at any time by contacting us.


We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. You will note that generally we rely on consent as a legal basis for processing your personal data.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing
To install the application and register you on our Platform (a) Identity
(b) Contact Consent
Performance of a contract with you
To process  purchases and deliver goods and services including managing payments and collecting money owed to us and Food Businesses

Marketing and Communications
Location Your consent
Performance of a contract with you

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey (a) Identity
(b) Contact
(c) Financial
(d) Profile
(e) Marketing and Communications Consent
Performance of a contract with you
Necessary to comply with a legal obligation

To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications Consent
Performance of a contract with you

To administer and protect our business and this Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)   (a) Identity
(b) Contact
(c) Device
(d) Technical Consent
Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Device
(d) Content
(e) Profile
(f) Usage
(g) Marketing and Communications
(h) Location Consent
To use data analytics to improve our Platform, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage Consent
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Device, Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
(g) Location Consent
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at the contact details provided herein.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, entering a competition, and product/service experience or other transactions.
You can set 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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


We may share your personal data with the parties set out below for the purposes set out in the table above.
• Internal Third Parties: being other companies in the Win Sustainably Group and its parent group or owners from time to time acting as joint controllers or processors and who are based in the UAE and provide IT and system administration services and undertake leadership reporting.
• External Third Parties such as:
o Food businesses with whom you have placed orders through the Platform;
o Delivery companies in respect of orders for which you have requested delivery;
o Visitors to the Platform in respect of any reviews posted by you;
o service providers acting as processors based the UAE who provide IT and system administration services;
o professional advisers acting as processors and controllers including lawyers, bankers, auditors and insurers based in the UAE who provide consultancy, banking, legal, insurance and accounting services; and
o Any regulators and other authorities based in the UAE who may require reporting of processing activities in certain circumstances; and
o Market Researchers, Fraud Prevention Agencies, Price Comparison Sites, Marketing Agencies, Partners and Sponsors of the Event, or group companies.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


Occasionally our external third parties maybe based outside of the UAE so their processing of your personal data will involve a transfer of data outside the UAE
Whenever we transfer your personal data out of the UAE, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UAE which give personal data the same protection it has in the UAE.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UAE.


We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any marketing, legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for no longer than is necessary for the purposes for which the personal data is being processed.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.


Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
• Right to Withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you, details of the processing activities and to check that we are lawfully processing it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
o If you want us to establish the data's accuracy.
o Where our use of the data is unlawful but you do not want us to erase it.
o Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
o You have objected to our use of your data but we need to verify whether we have overriding other grounds to use it.
• Object to processing. You also have the right to object where we are processing your personal data for direct marketing purposes.
If you wish to exercise any of the rights set out above, please contact us at the contact details provided herein.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). 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 to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Legal Entity: Win Sustainably Portal LLC
Email Address:
Postal Address: Office OFF3-058, Mohammed Saeed Harb Building, Port Saeed, Bur Dubai, PO Box 44320, Dubai, United Arab Emirates
You have the right to make a complaint at any time to the UAE Data Office , the UAE regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the UAE Data Office so please contact us in the first instance