PRIVACY POLICY

State of Qatar - Personal Data Privacy Protection Law
(Law No. 13 of 2016)
GRO Solutions LLC

Effective Date: October 1, 2025
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1. Introduction

GRO Solutions LLC (“we,” “our,” or “us”), registered at the Qatar Financial Centre under

QFC No. 04838, is committed to protecting the personal data of individuals in accordance

with the State of Qatar’s Personal Data Privacy Protection Law (Law No. 13 of 2016) and its

Executive Regulations, as well as applicable QFC Data Protection Regulations.

This Privacy Policy describes how we collect, process, store, and safeguard your personal

data when you access our website and use our services.

2. Data Controller

The entity responsible for the processing of your personal data is:

Entity GRO Solutions LLC

Registration - QFC No. 04838

Registered - Address Qatar Financial Centre, Doha, Qatar

Email - info@cupofcoffee.studio

3. Personal Data We Collect

We collect the following personal data directly from you when you interact with our website:

Data Category - Details

Full Name - Your first and last name, as voluntarily provided by you

Email Address - Your email address, as voluntarily provided by you

We do not collect sensitive personal data as defined under Qatari law.

4. Legal Basis for Processing

In accordance with Articles 4 and 5 of Law No. 13 of 2016, we process your personal data

on the following grounds:

• Your explicit, informed consent, obtained at the point of data collection

• The necessity of processing to fulfil a service requested by you or to take steps at

your request prior to entering into an agreement•

Compliance with legal or regulatory obligations applicable to GRO Solutions LLC

under QFC regulations and Qatari law

You may withdraw your consent at any time by contacting us at info@cupofcoffee.studio.

Withdrawal of consent shall not affect the lawfulness of processing carried out prior to such

withdrawal.

5. Purposes of Processing

Your personal data is processed for the following purposes:

• To register your account and provide access to our platform and services

• To communicate with you about our services, updates, and relevant announcements

• To respond to your inquiries and provide support

• To comply with applicable legal, regulatory, and QFC compliance obligations

• To improve and enhance our services and your user experience

6. Data Retention

We retain your personal data only for the period necessary to achieve the purposes outlined

in this policy, or as required by applicable Qatari law and QFC regulations.

• Account data (name and email) is retained for the duration of your active account and

for a maximum of 24 months after account closure or your last interaction with us.

• Upon expiry of the retention period, your data will be securely deleted or irreversibly

anonymised.

You may request early deletion of your data by contacting us at info@cupofcoffee.studio,

subject to any overriding legal retention requirements.

7. Your Rights Under Qatari Data Protection Law

Under Law No. 13 of 2016 and applicable QFC regulations, you have the following rights:

• Right of Access - You may request confirmation of whether we process your personal

data and obtain a copy thereof.

• Right to Rectification - You may request correction of any inaccurate or incomplete

personal data.

• Right to Deletion - You may request the deletion of your personal data where it is no

longer necessary for the purposes for which it was collected, or where you withdraw

your consent.

• Right to Object - You may object to the processing of your personal data in certain

circumstances.

• Right to Withdraw Consent - You may withdraw your consent to processing at any

time.

To exercise any of these rights, please contact us at info@cupofcoffee.studio. We will

respond to your request within 30 days.

8. Cross-Border Data Transfers

Your personal data may be transferred to and processed in jurisdictions outside the State of

Qatar for the purposes described in this policy. In such cases, we take all necessary steps to

ensure that:

• The receiving jurisdiction provides an adequate level of data protection as assessed

under Qatari law and QFC requirements

• Appropriate contractual and organisational safeguards are in place to protect your

data

• Your explicit consent for such transfer is obtained where required

9. Data Security

In accordance with Article 11 of Law No. 13 of 2016, we implement appropriate technical and

organisational measures to protect your personal data from unauthorised access, disclosure,

alteration, or destruction. These measures include:

• Encryption of personal data during transmission (TLS/SSL) and storage

• Strict access controls limiting data access to authorised personnel

• Regular security reviews and updates to our data protection practices

10. Disclosure to Third Parties

We do not sell or trade your personal data. We may disclose your data to third parties only in

the following limited circumstances:

• Trusted service providers who process data on our behalf under binding data

processing agreements (e.g., hosting providers, email service providers)

• Regulatory or governmental authorities where required by Qatari law, QFC

regulations, or a valid legal order

• Professional advisors (legal, audit) where necessary and under confidentiality

obligations

11. Cookies and Similar Technologies

Our website may use cookies and similar tracking technologies to enhance your browsing

experience. We obtain your consent before placing non-essential cookies. For more details,

please refer to our Cookie Policy [link to be inserted].

12. Children’s Data

Our services are not intended for individuals under the age of 18. We do not knowingly

collect personal data from minors. If we become aware that we have collected data from a

minor without appropriate parental or guardian consent, we will take prompt steps to delete

such data.

13. Complaints

If you have concerns about the way we process your personal data, you may contact us at

info@cupofcoffee.studio. You also have the right to submit a complaint to the relevant

authority:

• For matters under QFC jurisdiction: The QFC Regulatory Authority

• For matters under national Qatari law: The Compliance and Data Protection

Department at the Ministry of Transport and Communications

14. Changes to This Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes in our practices or in

applicable law. Material changes will be communicated via our website or by email. The

effective date at the top of this document indicates the date of the most recent revision.

15. Contact Information

For any questions or requests regarding this Privacy Policy or your personal data, please

contact:

Entity GRO Solutions LLC

QFC No. - 04838

Email - info@cupofcoffee.studio

Address - Qatar Financial Centre, Doha, Qatar