Privacy Policy

Data Controller Information

For this policy, the data controller is:

• • Legal Entity: PADO Software Design LLC
• • Trade License No: 1493330
• • Address: Office M17-249, Royal House, Hor Al Anz East, Dubai, UAE
• • Contact: privacy@cogo.xyz, Tel: +971 52 891 2066

Scope and CoGo's Role

This policy applies to the personal data CoGo collects as a Data Controller—that is, data about our direct users (you). When you use our platform to build applications that collect data from your own end-users, you are the Data Controller for that data, and CoGo acts as a Data Processor on your behalf, processing that data according to your instructions. Our obligations as a Data Processor will be governed by a separate Data Processing Addendum.

Personal Data We Collect

We collect the minimum data necessary to provide and improve our Service:

• • Identity and Contact Data: Name, email address, phone number.
• • Financial Data: Payment card details (processed securely by a third-party payment gateway; we do not store this information).
• • Technical Data: IP address, browser type, device information, operating system.
• • Usage Data: Information about how you interact with our Service, such as features used and time spent on the platform.

Legal Basis for Processing Data

We process your personal data based on the following legal grounds under UAE PDPL:

• • Performance of a Contract: To create your account, provide the Service, and process payments.
• • Your Explicit Consent: For sending marketing communications. You can withdraw this consent at any time.
• • Our Legitimate Interests: To improve our Service, ensure security, and prevent fraud.
• • Compliance with a Legal Obligation: To comply with applicable laws and regulatory requests.

Data Sharing and International Transfers

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

• • Service Providers: Trusted third parties who provide services on our behalf, such as payment processing and cloud hosting. They are contractually bound to protect your data.
• • Legal Authorities: If required by law or to respond to a valid legal process.

If we transfer personal data outside the UAE, we will ensure it is transferred to a country with an adequate level of data protection as recognized by the UAE Data Office, or we will implement appropriate safeguards such as Standard Contractual Clauses.

Data Security

We implement appropriate technical and organizational security measures, such as encryption and access controls, to protect your personal data from unauthorized access, alteration, disclosure, or destruction.

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Your Legal Rights as a Data Subject

Under the UAE PDPL, you have the following rights regarding your personal data:

• • Right to Access: Request a copy of the personal data we hold about you.
• • Right to Rectification: Request correction of inaccurate or incomplete data.
• • Right to Erasure (Right to be Forgotten): Request the deletion of your personal data where there is no compelling reason for us to keep it.
• • Right to Restrict Processing: Request the suspension of the processing of your personal data in certain circumstances.
• • Right to Data Portability: Request the transfer of your personal data to you or a third party in a machine-readable format.
• • Right to Object: Object to our processing of your personal data where we are relying on a legitimate interest.
• • Right to Withdraw Consent: Withdraw your consent at any time where we rely on consent to process your data.

To exercise any of these rights, please contact us at privacy@cogo.xyz.

Cookie Policy

This Cookies Policy explains how we use cookies and similar tracking technologies when you visit or use our website (the "Service"). It describes what these technologies are, why we use them, and your rights to control their use.