1. What is this?
This policy explains when and why we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others, and how it is kept secure.
This policy may change from time to time so please check this page occasionally to ensure that you’re happy with any changes.
2. Who we are
User Centric, (company number 17000623) with its registered office address is Business Center RAKEZ, Ras Al Khaimah, United Arab Emirates is the data controller in relation to the processing activities described below. This means that we decide why and how your personal information is processed.
Where this policy refers to “we”, “our” or “us” below unless it mentions otherwise, it’s referring to the particular company that is the controller of your personal information.
3. Data we collect and how we collect it
When you use this website, our products or services, the categories of information that we may collect about you and the way in which we collect it are as follows:
The personal information you give to us. This is information about you that you give to us by entering information via our website, social media platforms, or corresponding with us by phone, email, or otherwise, and is provided entirely voluntarily.
This includes information provided at the time of registering to use our site, subscribing to our mailing list/newsletter through our website, submitting a contact form on our website, registering interest to use our services/products, posting material, or requesting further services, (including accessing documentation and engaging in correspondence with us by phone, email or otherwise). Such information may consist of, but is not limited to, your title, name, email address, telephone numbers, information relating to the sale of service/products to you, and correspondence and communication details.
We may also ask you for information when you report a problem with our site. If you complete any surveys that we request you complete for research purposes, we will collect information in such circumstances as well. The information you give us may include your name, address, email address, phone number, inquiry details, and may include records of any correspondence and responses to any surveys.
Personal information we collect about you:
We may automatically collect details of transactions you carry out through the website, and your visits to our site, including, but not limited to, traffic data, location data, weblogs, and other communication data, and the resources you access. We may also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Please see Cookies for further information. We may also collect any personal information which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system, and platform.
4. How we use your personal information
The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.
Performance of the contract with you or take steps to enter into. We may use and process your personal information where we have supplied you (or continue to supply you) with any products or services, where we are processing an order from you, where we have arranged for the supply of another company’s products or services to you, or where you are in discussions with us about any new product or service. We will use this information in connection with the contract for the supply of services/products when it is needed to carry out that contract with you or for you to enter into it. Please see the Data we collect and how we collect it above for details of the types of personal information we process for these purposes.
Legitimate interests. We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
for marketing activities (other than where we rely on your consent to contact you by email or text with information about our products and services, as explained below in Consent for data processing);
for analysis to inform our marketing strategy, and to enhance and personalise your client experience (including to improve the recommendations we make to you on our website);
to monitor the usage of our site, record traffic flows, and carry out research about its user’s demographics, interests, and behaviour in order to better understand the users of its website and clients;
to correspond or communicate with you, including about our services and any changes or improvements to our website or services;
to carry out database and website administration;
to verify the accuracy of data that we hold about you and create a better understanding of you as a client;
for network and information security in order for us to take steps to protect your information against loss or damage, theft, or unauthorised access;
for prevention of fraud and other criminal activities;
to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
to assess and improve our service to clients;
for the management of queries, complaints, or claims; and
for the establishment and defense of our legal rights.
Consent for data processing. We may use and process your personal data where you have consented for us to do so. This includes contacting you with marketing information about our products and/or services if you have:
signed up to our mailing list/e-newsletters via our website or another medium where available; or
when you refresh your marketing preferences and provide consent when responding to a request from us to do so.
You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent for further details.
Legal requirement. We will use your personal information to comply with our legal obligations: (i) to assist any public authority or criminal investigation body; (ii) to identify you when you contact us; and/or (iii) to verify the accuracy of data we hold about you.
5. Data anonymisation and use of aggregated information
Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.
6. Others who may receive or have access to your personal information
Our suppliers and service providers
We may disclose your information to our third-party service providers, agents, subcontractors, and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include providers of information technology, case management systems, marketing agencies, cloud service providers (such as hosting and email management), data analysis, data backup, security services, advertising agencies, and administrative services.
When we use third-party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts, or to protect the rights, property or safety of our visitors and clients.
When disclosing your personal information to third parties, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
Click here to read our section on data protection
7. Where we store your personal information
All information you provide to us is stored on our secure servers which are located within the European Economic Area (EEA).
If at any time we transfer your personal information to or store it in, countries located outside of the EEA (for example, if our hosting services provider changes) we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA.
If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
8. How long we keep your personal information for
We will not keep your information for longer than is necessary for the purposes for which we collect it unless we believe that the law or other regulation requires us to preserve it.
If you have made an inquiry or contacted us via our website, we will store your information for as long as is reasonably required to deal with your inquiry. If you become a client and open an account with us, we will retain your personal information for as long as your account is active. If your account is dormant for more than 2 years, we’ll send you a reminder, after which we will close your account. Once your account is closed, we will retain your personal information in case of any queries from you or in case you decide to re-activate your account for a period of 2 years from the date your account is closed.
If you have signed up to receive marketing from us we will store your personal information for as long as you are subscribed to our marketing list. If you unsubscribe or your subscription expires because you do not interact with our marketing emails for over 3 years, we will keep your email address on our suppression list to ensure that we do not send you marketing emails.
If you have contacted us with a complaint or query we will store your personal information for as long as is reasonably required to resolve your complaint or query.
We retain technical information obtained via Google Analytics for 26 months from the date it is collected. This information is converted into aggregated data to ensure that it is anonymised.
The only exceptions to the above are where:
we may need your personal information to establish, bring or defend legal claims or to comply with a legal or regulatory requirement;
the law requires us to hold your personal information for a longer period, or delete it sooner;
you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below); or
in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
When it is no longer necessary to retain your data, we will delete the personal information that we hold about you from our systems. After that time, we may aggregate the data (from which you cannot be identified) and retain it for analytical purposes.
9. Security and links to other sites
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
11. Our marketing
We may collect your preferences to receive marketing information directly from us by email in the following ways:
if you sign up to our mailing list/e-newsletters via our website or other medium where available, we will ask you if you would like to provide your consent to receive marketing information directly from us; or
from time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.
You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above.
Please see Withdrawing your Consent and Objecting to our use of your personal information and automated decisions made about you above for further details on how you can do this.
12. Your rights
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.
Accessing your personal information. You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Correcting and updating your personal information. The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.
Withdrawing your consent. Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
Objecting to our use of your personal information and automated decisions made about you. Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under How we use your personal information, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data. You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool. You may also contest a decision made about you based on automated processing by contacting us at the details at the end of this policy.
Erasing your personal information or restricting its processing. In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request. You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
Transferring your personal information in a structured data file (“data portability”). Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How we use your personal information and we process this information electronically, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used, and machine-readable form, such as a CSV file. You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Complaining to the UK data protection regulator. You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.
13. Changes to this policy
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is earlier. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.
14. Contact us
If you have any questions or concerns about cookies or your privacy when using this Site, please contact us using the form on our website.