Privacy policy

Data Privacy Policy

(Last Updated: [•] December 2025)

Introduction

For the purpose of this Privacy Policy (the “Policy”):

“You,” “Your” and/or “User” shall refer to the party seeking to be provided with the Moments’ Services from Kayan for Training and Education Services LLC as defined herein.
“We,” “Us,” “Our(s),” and/or “Kayan” shall refer to Kayan for Training and Education Services and/or any of its affiliates, as the case may be.
“Data” shall refer to any information, whether in digital or physical form, that is collected, processed, stored, or transmitted by Us.
“Service(s)” shall refer to the services offered or managed by Us through the Moments Platform, or any other platform owner or managed by Us.
“External Parties” shall refer to individuals, organizations, or entities outside of Us, including partners, vendors, contractors, and any third-party service providers.
“Moments Platform” shall refer to the Moments website and application, owned by Us.
“Moments Account”, and/or “Account” shall refer to the account that the User creates to access the Services and use the Moments Platform.

Unless otherwise defined in this Policy, capitalized terms defined in Terms & Conditions shall have the same meanings in this Policy.
The objective of the Policy is to ensure that necessary guidance is in place for the Service Users to ensure that the Services delivered are in line with Our standards.
This Privacy Policy describes the Personal Data We collect, how it’s used and shared, and Your choices regarding this Personal Data.
By accessing or using the Services, signing a service order form with us specific to you or your organization, or clicking a button or checking a box marked "I Agree" (or something similar), you signify that you have read, understood, and agree and consent to this Privacy Policy, whether or not you are a registered user of our Services. If you do not accept this Privacy Policy, then you are expressly prohibited from using the Services and you must discontinue use immediately.

Data Collection

We may collect, use, store and transfer the following information to provide, improve and protect Our Service and the Products.
You may give Us Personal Data which is any information that alone or in combination with other information can identify You, by interacting with and/or visiting the Moments Platform, interacting with Our Service, or by corresponding with Us by phone, e-mail, or otherwise. The Personal Data includes the following data which are referred to in this Policy as “Your Personal Data”:

You provide personal information when You interact with Our Service. The personal information You give Us may include Your name, company, mailing address, email address, phone number, country, feedback and any other information You choose to provide Us with;
We may collect certain technical information through the use of log files and servers. Web and application servers create log files automatically as part of their setup and configuration. Information in a log file may include IP address, browser type, Internet service provider, date/time stamps, Media Access Control (MAC) address, file requested, and other usage information and statistics.
If You access the Service from a mobile phone, tablet, automobile, or other electronic device, We may collect and store information such as device type, operating system version and type, unique identifiers (such as mobile advertising ID, VIN, and MAC address) and other related information for that device.
We may also collect location information from devices You use while accessing the Our Service. Depending on the device and operating system, device-based location information may be derived from GPS and nearby wireless signals such as cell towers, Wi-Fi networks, and Bluetooth beacons. We will not collect Your device-based location information unless You have permitted the Moments Platform to access location services on Your device. You can disable this access at any time in Your system settings.
We may collect information which tells Us how You use Our Service, including which pages You view and how You interact with the Service. We automatically receive and record information from Your use of the Services, including but not limited to: Moments Platform usage, Your IP address browser type, Internet service provider, referring/exit pages, operating system, date/time stamp, clickstream data, and cookie information. This information is used to optimize Your user experience. Generally, the Services automatically collect usage information, such as the number and frequency of users of the Services. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify You personally. This type of aggregate data enables Us and third parties authorized by Us to figure out how often individuals use parts of the Services so that We can analyse and improve them.
We may collect information which tells Us Your communication preferences;
We may collect Personal Data which You voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that You share in an open forum may be viewed and used by others without any restrictions. Our Services include publicly accessible blogs, community forums, or private messaging features. The Services may also contain links and interactive features with various social media platforms (e.g., widgets). If You already use these platforms, their cookies may be set on Your device when using Our Services or other services. You should be aware that We are unable to control such uses of Your information when interacting with a social media platform, and by using such services You assume the risk that the Personal Data provided by You may be viewed and used by third parties for any number of purposes.
We may receive Personal and/or Anonymous Data about You from companies that provide Our Services by way of a co-branded or private-labelled website or companies that offer their products and/or services on Our Services. These third-party companies may supply Us with Personal Data. We may add this information to the information We have already collected from You via Our Services in order to improve the Services We provide.

Usage of Collected Data

We may use Personal Data for the following purposes:

To provide and maintain Our Service, including to monitor the usage of Our Service.
To manage Your Account, including Your registration as a User of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered User.
To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including security updates, when necessary or reasonable.
To manage and attend Your requests to Us, including customer support.
For business transfers, including to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about Our Service Users is among the assets transferred.
For safety and security. We use information about You and the Service You use to verify accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of Service policies.
For research and development. We are always looking for ways to make Our Services smarter, faster, more secure, integrated and useful to You. To that end, We use collective learnings about how people use Our Services and feedback provided directly to Us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services.
For other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns and to evaluate and improve Our Service, products, services, marketing and Your experience.

Sharing Your Data

We may share Your Personal Data as discussed below:

We use trusted third parties (i.e. IT services, analytics services, etc.) to help Us provide, improve, protect, and promote Our Website and Our Service. These third parties will access Your information only to perform tasks on Our behalf in compliance with this Policy, and we’ll remain responsible, to a reasonable extent, for their handling of Your information per Our instructions.
We may transfer Your Personal Data in the event of a sale, reorganisation, or merger of Kayan.
We may share Your Personal Data with regulatory bodies, law enforcement entities, and judicial courts, and others as required by law. We may use Your Personal Data where required by law, where We believe it is in Our legitimate business interest, or where it is necessary to protect Our legal rights, interests and the interests of others, We may use information about You in connection with legal claims, compliance, regulatory, and audit functions.
We may disclose Your Personal Data for any other purpose with Your consent.

Data Retention and Deletion

Kayan retains User Data for as long as reasonably necessary for the aforementioned purposes, 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 of a complaint or if We reasonably believe there is a prospect of litigation in respect of Our relationship with You. In the event that this Policy contradicts any previous policies, and/or terms & conditions, the provisions applicable to Personal Data under this Policy shall prevail.
Users may request deletion of their accounts at any time.
Following an Account deletion request, Kayan shall delete the User’s Account and the Personal Data associated with such Account, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, because of an issue relating to the User’s account such as an outstanding credit or an unresolved claim or dispute, or as mandated by the Terms & Conditions.
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.

Your Legal Rights

We process Your Personal Data based on the following legal bases:

Where processing is necessary for Us to perform the Services, subject to the obligation to be entered into or have entered into with You;
Where it is necessary for Our legitimate interests, or those of a third party, provided that Your interests and fundamental rights do not override those interests; and
Where We need to comply with a legal or regulatory obligation.

You have certain rights with respect to the access, correction, restriction, and erasure of Your Personal Data stored on Our Service at any time. You can exercise any of these rights at any time by contacting Us. Your rights include the following:

Upon request, We shall provide any information relating to Your Personal Data and Our processing of Your Personal Data in a concise, transparent, intelligible, and easily accessible form, using clear and plain language. The information shall be provided in writing or by other means, including, where appropriate, by electronic means within thirty (30) days of a written request.
You have the right to ask Us to rectify any inaccurate or incomplete Personal Data on Our Service. If We have given Your Personal Data to any third parties, We will notify those third parties that We have received a request to rectify Your Personal Data, unless doing so proves impossible or involves disproportionate effort. Those third parties should also rectify the Personal Data they hold – however, We are not in a position to audit those third parties to ensure that the rectification has occurred.
You can ask Us to erase Your Personal Data stored on Our Service. If We receive a request to erase Your Personal Data, We will ask You if You want Your Personal Data to be removed entirely or if You want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose data We have erased so You may be contacted again by Us, should We come into possession of Your Personal Data at a later date.
We only process Your Personal Data where We have the legal basis for doing so. You have the right to ask Us to suspend or otherwise restrict the processing of Your Personal Data where:

You challenge the accuracy of the Personal Data;
The processing is unlawful but You do not want Us to erase the Personal Data;
We no longer need the Personal Data for the purposes of the processing, but You want Us to hold it as You need it to establish, exercise, or defend legal claims; or You have objected to Our use of Your Personal Data, but We need to verify whether We have legitimate grounds to use it.

Where We Store and Transfer Your Data

Keeping Your Personal Data secure is a top priority for Us. To that end, We comply with industry-standard best practices to secure Your information. We use various data hosting service providers to host the information We collect, and We use technical measures to secure Your Data. While We implement safeguards designed to protect Your Personal Data, no security system is impenetrable and due to the inherent nature of the internet, We cannot guarantee that Data, during transmission through the internet or while stored on Our systems or otherwise in Our care, is absolutely safe from intrusion by others.
Kayan may store and use Your Personal Data in secure servers across various jurisdictions, including but not limited to the country in which You reside; any Personal Data provided to Kayan may be transmitted to or within those jurisdictions.
Whenever We transfer Your personal data out of any country or jurisdiction, 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. When required, We will use the specific contractual clauses approved by the competent authority(s), when applicable and to the extent such action is necessary.
Where We will transfer Personal Data of EU Residents, We will only transfer Your Personal Data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where We use certain service providers, We may use specific contracts which provide an adequate level of protection for personal data.

Please contact Us if You want further information regarding transferring Your Personal Data out of your country of residency.

Cookies

Cookies are small text files containing a unique identifier, which are stored on Your Device so that Your Device can be recognised when You're using a particular website or mobile app. Some cookies may be used only for the duration of Your visit, and others may be used to measure how You interact with services and content over time.
We use/may use cookies and/or other tracking technologies to distinguish You from other Users of the Service and to remember Your preferences. This assists Us in providing You with a good experience when You use the Service and also allows Us to improve the Service. Cookies can also be used to help Us detect fraudulent activity or to prevent security breaches, so We may record information about Your device within the cookie.
The reasons We use cookies are as follows:

The cookies We place on Your hard drive are known as "first-party cookies". We use both session cookies and persistent cookies. A session cookie expires when You close Your browser. A persistent cookie remains on Your hard drive for an extended period of time. You may be able to remove persistent cookies by following directions provided in Your browser's "help" section. If You do not accept first-party cookies, You may still use Our Service, but Your ability to use some areas of Our Service, and the ability to stay logged in, will be limited.
We may use Google Analytics with the Service to help Us understand how You use the Service. You can learn about how to opt-out of Google Analytics here.

Note that deleting or blocking cookies may impact Your experience on Our Service, as some features may not be available. Certain options You select are browser and device specific.

Social Media Widgets

Moments Platform includes social media features such as the Facebook “Like” button and might include widgets such as the share this button or other interactive mini programs. These features may collect Your IP address, which page you are visiting on Our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on the Moments Platform. Your interactions with these features are governed by the privacy policy of the company providing it.

Children’s Privacy

By using the Service, You represent that You are at least the age of majority in Your jurisdiction of residence. Moreover, You acknowledge that the access to Your Account is Your responsibility in its entirety. Kayan will have no liability in any way if Your Account was used by a minor dependant, without supervision. You are providing Your consent for Your child’s use of Your Account whenever Your Account is accessed by such child /minor independent. Please contact Us if You believe We have collected Personal Data about a child without consent from their parent or guardian so We can take action to prevent such access and to delete their Personal Data from Our Service.

Security

To protect Your Personal Data, We take reasonable precautions and follow industry standard practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. However, information shared online is never 100% secure.
We will only retain Your Personal Data for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 unauthorized 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 requirements.
We use the Personal Data We collect in ways that are relevant and compatible with the purpose for which that Personal Data was collected or provided to Us as disclosed in this Policy. We will take steps to ensure that all Personal Data collected, processed, and/or stored is protected from destruction, corruption, or use in a manner inconsistent with Our policies or the purpose for which We received it.
Personal Data may be accessed by persons within Our organization, or Our third-party service providers, who require such access to carry out the purposes described in this Policy, or otherwise permitted or required by applicable law.

Changes to this Policy

We may update Our Privacy Policy from time to time. We will, with no obligation to, notify You of any changes by posting the new Policy on the Moments Platform.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective, and update the "Last updated" date at the top of this Policy.
You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.

Governing Law

This Privacy Policy and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation shall be governed by and construed in accordance with the laws of the Hashemite Kingdom of Jordan.
Each party irrevocably agrees that the courts of the Hashemite Kingdom of Jordan shall have exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with this Privacy Policy or its subject matter or formation.

Contact

If You have any questions about this Privacy Policy, You can contact Us:

By email: Hello@beingmoments.com

I confirm that I have read, understood, and agree to the Privacy Policy of Moments. I consent to the collection, use, storage, and electronic processing of my personal data in accordance with the Privacy Policy.