In addition to the specific purposes for which we may process your personal data set out in this Section, we may process any of your personal data identified in this Policy where necessary for:
We will only use your personal data in a fair and reasonable manner, and where we have a lawful reason to do so. We primarily use your information for the following purposes.
To provide products and services. To provide products and services to you across the Platform, including our third-party specialised payment providers.
To deliver marketing and advertising. We need your consent to use your information for specific purposes – such as marketing, brand communication and personalised advertising. If you consent, we will use your information as follows:
Other uses of your information. Other than where we have sought your consent, we rely on two other individual bases to lawfully use your information. First, we need to use your information in certain ways to provide our products or services to you, in accordance with our contract with you. In this case, it is necessary for us to use your information so that we can deliver the products or services you have chosen. In certain cases, we may use your information where necessary to further our legitimate interests, where those legitimate interests are not overridden by your rights or interests, including:
You have the right to object to any of the above uses of your information, please contact us if you wish to do so. We will consider all objections reasonably, but there may be legal reasons where we deem that the use of your information is still appropriate. We are committed to explain our decision to you in a timely manner.
We do not store any account-related information or any payment instrument (including credit card) details. We are not liable for any loss or damage caused to you as a result of any disclosure (inadvertent or otherwise) of any information concerning your accounts (including third-party account) or payment instruments in the course of any transactions or payments made for any products and/or services by you through the Platform.
We pass information to third-parties. In some instances, we disclose personal information to third-parties when it is necessary to deliver a service or product, or to help us improve your experience with us, or when we are required to do so by contract or law. “Third-parties” include agents, subcontractors, sponsors and other associated organisations. We have in place contracts to ensure the information remains secure and limited in use, and if we do not have a legitimate business reason to pass on your information, we will ask you to give consent first. Some examples of when we share your information are below:
Third-parties who pass information to us. Our subscriptions services sometimes use additional information such as telephone numbers or postcodes from third-parties (like list brokers, researchers or telemarketing agents, who have gathered this information lawfully) to help us to contact you with important service updates via phone or post or to help us make marketing decisions. This includes advertising (by ourselves or via advertising partners) to groups of people with particular interests. These third-parties may give us access to your personal information, if you have allowed them to do so. We may also work with third-parties to identify individuals who may be interested in our products and services or in some cases our sponsors / advertisers’ products and services. These third-parties may give us access to your personal information, if you have allowed them to do so. The collection, use, and disclosure of information by these third-parties are described in their own privacy policies, and consequently may differ from that set out in this Policy. We are not responsible for those third-party privacy policies, and you should ensure that you have read and understood all applicable privacy policies before proceeding.
Data Retention policy. We securely store your information, and hold it for as long as we need to in order to provide our products and services to you in accordance with (i) applicable law, or (ii) as long as is set out in any relevant contract you have with us. We review our retention periods for personal information regularly. If you have not interacted with us in any way, we will generally no longer hold your information after 7 years from its last use. We would only keep it for longer than this if we are required to by law or if we have a legitimate reason to do so. Sometimes we may need to keep it for longer periods for reasons such as tax and other financial regulatory mandates.
Data Erasure Policy. If you request for us to no longer contact you, for example with marketing communications, we will retain the minimum amount of information about you so that we can ensure we remove you from any future communications. Please note that if you ask us to completely remove all information about you, and you subsequently use our products and services at a later date, we will no longer be able to recognise your previous request not to be contacted, which is why we would keep it and suppress it in line with industry standards.
Storing and transferring information internationally. As the internet is a global environment and we work with third-parties across the globe, collecting and using your personal information may involve the transfer of this information internationally, including outside of the European Union. By using our products and services, you acknowledge and agree to your personal information being transferred in this way, including to jurisdictions outside the EEA. We will maintain strict policies to ensure all information that is transferred is done so safely and securely.
Keeping your information safe. We take information security seriously and have policies and procedures in place to ensure the information we hold on you remains safe. We limit who has access to your information and ensure that those who do are bound by contracts to keep your information confidential and safe.
Individuals under 16. We do not, intentionally or knowingly, process personal information of individuals under the age of 16. We will make every effort to delete any details of such users where a parent or guardian has informed us that these details have been collected.
You may exercise your rights which are available to data subjects in relation to your Personal Information which is being held or processed by us.
Rights under the GDPR. Under certain circumstances, you have the right to:
Rights under the CCPA. If the processing of your personal information is subject to the CCPA, you are entitled to the rights listed below.
Rights in general. We provide you the right to keep your Personal Information held by us accurate and up-to-date. If at any time you would like to:
you may do so by contact our Data Protection Officers (details provided in this Policy).
Do note that if you exercise any of the above rights, we may need to request specific information from you to help us confirm your identity and to ascertain that you are entitled to make such a request. This is to ensure that your personal data is not disclosed to any person who is not authorised to receive it. For the exercise of certain rights, you may be required to approach the designated data protection officer. You may be charged a fee for the processing of your request, particularly in case of frivolous, excessive, or manifestly unfounded requests. Do note that your rights listed in this Policy are not absolute and are subject to limitations as per the applicable data protection laws.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the European Economic Area (EEA) unless the transfer meets certain criteria. We and many of our third-parties service providers are based outside the EEA, including in UAE and India, so the processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
For the purposes of your data collected through the Platform, held by us, or processed by us, the data controller (under GDPR and other laws which use a similar concept) and the business/service provider (under CCPA and other laws which use a similar concept) is RD&X Group DMCC. If you have questions about this Policy or about your personal information, or if you wish to exercise a right regarding your information, please contact the Data Protection Officer as under.
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