- 1. IMPORTANT INFORMATION AND WHO WE ARE
- 2. THE DATA WE COLLECT ABOUT YOU
- 3. HOW IS YOUR PERSONAL DATA COLLECTED?
- 4. HOW WE USE YOUR PERSONAL DATA
- 5. DISCLOSURES OF YOUR PERSONAL DATA
- 6. INTERNATIONAL TRANSFERS
- 7. DATA SECURITY
- 8. DATA RETENTION
- 9. YOUR LEGAL RIGHTS
- 10. GLOSSARY
1 IMPORTANT INFORMATION AND WHO WE ARE
- 1.1.2 This Website is not intended for children and we do not knowingly collect data relating to children.
Name: Anya Zakharova
Email address: email@example.com
Telephone number: +971 43 305 222
Postal address: Index Tower, Unit 1611, Floor 16, DIFC, PO Box 507284 Dubai, UAE
- 1.2.3 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
- 1.3.2 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.4 Third-party links
2 THE DATA WE COLLECT ABOUT YOU
- 2.1 Personal data, or personal information, means any information relating to an identified or identifiable living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
- 2.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- 2.2.1 Identity Data includes first name, last name, title, date of birth and gender.
- 2.2.2 Contact Data includes postal address, email address and telephone numbers.
- 2.2.3 Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, language settings, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
- 2.2.4 Profile Data includes your interests, preferences, feedback and survey responses.
- 2.2.5 Usage Data includes information about how you use our Website.
- 2.2.6 Marketing and Communications Data includes preferences in receiving marketing from us and our third parties and your communication preferences.
- 2.4 We do not collect any Special Categories of 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 (where used for ID purposes).
- 2.5 We do not collect any information about criminal convictions and offences.
- 2.6 If you fail to provide personal data
- 2.6.1 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.
3 HOW IS YOUR PERSONAL DATA COLLECTED?
- 3.1 We use different methods to collect data from and about you including through:
- 3.1.1 Direct interactions. You may give us your Identity Data, Contact Data, Profile Data and Marketing and Communications Data by corresponding with us by post, phone, email, filling in forms on our Website, or otherwise. This includes personal data you provide when you:
- 18.104.22.168 subscribe to our newsletter;
- 22.214.171.124 request marketing information to be sent to you;
- 126.96.36.199 confirm to us that you would like to be contacted by a third party who may be able to provide you with services;
- 188.8.131.52 enter a survey; or
- 184.108.40.206 give us feedback or contact us.
- 3.1.2 Automated technologies or interactions. As you interact with our Website 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookies policy for further details.
- 3.1.3 Third parties or publicly available sources. We may receive personal data about you from third parties as set out below:
- 220.127.116.11 Identity Data and Contact Data from our providers of technical services.
- 18.104.22.168 Technical Data from providers of our Website analytics services and advertising networks.
- 22.214.171.124 Identity Data and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the European Union.
4 HOW WE USE YOUR PERSONAL DATA
- 4.1 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:
- 4.1.1 Where you have consented to our use of your personal data. You have the right to withdraw such consent at any time by contacting us.
- 4.1.2 Where we need to perform the contract we are about to enter into or have entered into with you.
- 4.1.3 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- 4.1.4 Where we need to comply with a legal or regulatory obligation.
- 4.2 Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
- 4.3 Purposes for which we will use your personal data
- 4.3.1 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 bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
- 4.3.2 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.
- 4.1 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:
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To manage our relationship with you which will include:
|To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
||Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Website, marketing, customer relationships and experiences||
||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about services that may be of interest to you||
- 4.4 Marketing
- 4.4.1 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
- 4.5 Newsletter
- 4.5.1 We may use your Identity Data, Contact Data, Technical Data, Usage Data, Profile Data and Marketing and Communications 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 industry insights may be relevant for you (we call this marketing).
- 4.5.2 You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.
- 4.6 Third-party marketing
- 4.6.1 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
- 4.7 Opting-out
- 4.7.1 You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
- 4.7.2 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of other transactions.
- 4.8 Cookies
- 4.9 Change of purpose
- 4.9.1 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.
- 4.9.2 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.
- 4.9.3 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.
5 DISCLOSURES OF YOUR PERSONAL DATA
- 5.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.3.2 above.
- 5.1.1 Internal Third Parties as set out in the Glossary.
- 5.1.2 External Third Parties as set out in the Glossary.
- 5.2 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.
6 INTERNATIONAL TRANSFERS
- 6.1 We do not transfer your personal data outside the European Economic Area (EEA).
7 DATA SECURITY
- 7.1 We have put in place appropriate 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.
- 7.2 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.
8 DATA RETENTION
- 8.1 How long will you use my personal data for?
- 8.1.1 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 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.
- 8.1.2 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.
- 8.1.3 In some circumstances you can ask us to delete your data: see 9.1.3 below for further information.
- 8.1.4 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.
9 YOUR LEGAL RIGHTS
- 9.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below:
- 9.1.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to (i) receive a copy of the personal data we hold about you; (ii) understand how and why we are using the personal data; and (iii) check that we are lawfully processing it.
- 9.1.2 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.
- 9.1.3 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.
- 9.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- 9.1.5 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- 9.1.6 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.
- 9.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. 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.
- 9.2 If you wish to exercise any of the rights set out above, please contact us.
- 9.3 No fee usually required
- 9.3.1 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 may refuse to comply with your request in these circumstances.
- 9.4 What we may need from you
- 9.4.1 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.
- 9.5 Time limit to respond
- 9.5.1 We try to respond to all legitimate requests within one month. Occasionally it may 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.
- 10.1 Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- 10.2 Internal Third Parties means other companies in our corporate group.
- 10.3 External Third Parties means:
- 10.3.1 Service providers acting as data processors who provide us with cloud computing, analytics, payment, project management, marketing, and hosting services.
- 10.3.2 Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- 10.3.3 HM Revenue & Customs and other authorities who require reporting of processing activities in certain circumstances.
- 10.4 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- 10.5 Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.