|S. No.||Type of Information||Document Data|
|2.||Date of Release||1 October 2018|
|4.||Document Version No.||V 1.0|
|7.||Document Reviewer/Approver||Founder & Managing Partner|
Document Update Summary
|Version No.||Revision Date||Nature of Change||Date Approved|
This is the privacy notice of Compport IT Solution, UAE. In this document, “we”, “our”, or “us” refer to CIS.
Compport IT Solutions, a UAE Company, duly established under the law of the Dubai Economic Department, License No. 814555, United Arab Emirates, being registered and licensed in the Emirate of Dubai, having its legal domicile at 20th Floor, 48, Burj Gate Tower, Sofitel Hotel Sheikh Zayed Complex, Downtown, Dubai, P.O.Box 36615, United Arab Emirates, and represented herein by its authorized signatory, hereinafter referred to as “CIS”
- This is a notice to inform you of our policy about all personal information that we record about you. It sets out what information we collect from you and the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We regret that if there are one or more points below with which you are not happy, you can raise your concern and revert back to us at mail Dpo@compport.com (Data Protection officer)
- We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
- We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
- Our policy complies with local data protection laws, including that required by the EU General Data Protection Regulation (GDPR).
- The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, through this privacy note and you can also visit knowyourprivacyrights.org for more information.
- Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you
- Information we process because we have a contractual obligation with you
1.1. When you are receiving service from us or have received some services earlier from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
1.2. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
1.3. To deliver services to our customer, we time to time use services of third party service providers such as AWS (cloud service provider) for hosting of our application and database. We have agreement with them to appropriately protect & secure customer’s information stored or transmitted to them.
1.4. We may use it in order to:
1.4.1. Verify your identity for security purposes
1.4.2. Provide you with our services
1.4.3. Provide you with suggestions and advice on services and how to obtain the most from using our website
1.4.4. We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
1.4.5. Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
1.4.6. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
- Information we process with your consent
2.3. Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
2.4. Except where you have consented to our use of your information, we do not use your information in any way that would identify you personally.
2.5. We continue to process your information until you withdraw your consent.
2.6. You may withdraw your consent at any time by instructing us mail Dpo@compport.com (Email address for DPO). However, if you do so, you may not be able to use our website or our services as normal. Compport will remove the personal data on receipt of specific request from you at mail Dpo@compport.com (Email address for DPO)
- Information we process for the purposes of legitimate interests
3.1. We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
3.1.1. Where we process your information on this basis, we do after having given careful consideration to:
3.1.2. Whether the same objective could be achieved through other means
3.1.3. Whether processing (or not processing) might cause you harm
3.1.4. Whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
3.2. For example, we may process your data on this basis for the purposes of:
3.2.1. Record-keeping for the proper and necessary administration of our services
3.2.2. Responding to unsolicited communication from you to which we believe you would expect a response
3.2.3. Protecting and asserting the legal rights of any party
3.2.4. Insuring against or obtaining professional advice that is required to manage business risk
3.2.5. Protecting your interests where we believe we have a duty to do so
- Information we process because we have a legal obligation
4.1. We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
4.2. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation.
4.3. This may include your personal information.
Specific uses of information you provide to us
- Information provided on the understanding that it will be shared with a third party
5.1. Your information may be stored, transferred or used by a third party for providing our services to you as normal. Please note that this Privacy Statement does not extend to any third party or any third party sites linked to this web site.
5.2. In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
5.3. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
5.4. To deliver services to our customer, we time to time use services of third party service providers such as AWS(cloud service provider) for hosting of our application and database. We have agreement with them to appropriately protect & secure customer’s information stored or transmitted to them.
5.5. Provided your request is reasonable and there is no legal basis for us to retain it, then we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at Dpo@compport.com (Email address for DPO)
- Complaints regarding content on our website
6.1. We attempt to moderate content on our website
6.2. If you complain about any of the content on our website, we shall investigate your complaint.
6.3. If we feel it is justified or if we believe the law requires us to do so, we shall take appropriate actions while we investigate.
6.4. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
- Sending a message to our support team
7.1. When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
7.2. We record your request and our reply in order to increase the efficiency of our business processes-
- Safeguarding the personal data
8.1. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service. Compport will use this personal data in accordance with the purpose set forth in this Privacy Statement and is committed to safeguarding the personal data collected.
9.1. When we receive a complaint, we record all the information you have given to us.
9.2. We use that information to resolve your complaint.
9.3. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
9.4. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
- Affiliate and business partner
10.1. This is information given to us by you in your capacity as an affiliate of us or as a business partner (Please mention any channel partner name?), It allows us to recognize visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.
10.2. The information is not used for any other purpose.
10.3. We undertake to preserve the confidentiality of the information and of the terms of our relationship.
10.4. We expect any affiliate or partner to agree to reciprocate this policy.
Use of information we collect through automated systems when you visit our website</h3 >
11.1. Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalized experience and the website owner with statistics about how you use the website so that it can be improved.
11.2. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
11.3. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
11.7.1. To track how you use our website
11.7.2. To record whether you have seen specific messages we display on our website
11.7.3. Analysis of Cookie data for marketing and performance
11.7.4. To track your information for Marketing communication
11.7.5. To keep you signed in our site
How can I control my cookies?
- Browser controls
12.1. You can use your web browser to:
12.1.1. delete all cookies;
12.1.2. block all cookies;
12.1.3. allow all cookies;
12.1.4. block third-party cookies;
12.1.5. clear all cookies when you close the browser;
12.1.6. open a ‘private browsing’ / ‘incognito’ session, which allows you to browse the internet without storing local data; and
12.1.7. install add-ons and plug-ins to extend browser functionality.
12.2. Where to find information about controlling cookies
12.2.1. Internet Explorer cookies information
12.2.2. Chrome cookies information
12.2.3. Firefox cookies information
12.2.4. Safari cookies information
12.2.5. Opera cookies information
12.3. Useful information
12.3.1. A number of websites provide detailed information on cookies, including AboutCookies.org and AllAboutCookies.org.
12.3.2. The Internet Advertising Bureau website Your Online Choices allows you to install opt-out cookies across different advertising networks.
12.3.3. Google has developed a browser add-on to allow users to opt-out of Google Analytics across all websites which use this popular analytics product.
12.3.4. New technologies such as Mozilla’s Do Not Track allow you to tell websites not to track you.
12.3.5. Internet Explorer has a feature called Tracking Protection Lists which allows you to import a list of websites you want to block.
- Personal identifiers from your browsing activity
13.1. Requests by your web browser to our servers for web pages and other content on our website are recorded by using tools/technology and help from third party service providers such as Google Analytics.
13.2. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
13.3. We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
13.4. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
- Our use of re-marketing
14.1. Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our services when you visit some other website.
14.3. Disclosure and sharing of your information
- Information we obtain from third parties
15.1. Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. However we use authorized sources to collect the information still we have no control on type and in manner the data is collected by third party
- Third party advertising on our website
16.1. Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
16.3. We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
- Data may be processed outside the European Union
17.1. Our website is hosted in United States of America.
17.2. We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
17.3. We use services of third party including cloud service provider for our software hosting such as AWS with data centers in _______________
17.4. Accordingly data obtained could be processed outside the European Union.
17.5. We use the following safeguards with respect to data transferred outside the European Union:
17.5.1. The processor is within the same corporate group as our business or organization and abides by the same binding corporate rules regarding data processing.
17.5.2. The data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union
17.5.3. We comply with a code of conduct approved by a supervisory authority in the European Union
17.5.4. We are GDPR compliant under compliant requirements & mechanism as provided for in the GDPR
17.5.5. Both our organization and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to protection of your information
Access to your own information
- Access to your personal information
18.1. At any time you may review or update personal identifiable information that we hold about you, by signing in to your account on our website.
18.2. To obtain a copy of any information that is not provided on our website you may send us a request at Dpo@compport.com.
18.3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
- Removal of your information
If you wish us to remove personally identifiable information, you may contact us at Dpo@compport.com.
This may limit the service we can provide to you and fulfilment of the business contract you might have entered with us.
- Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
- Use of site by children
21.1. We do not provide services for purchase by children, nor do we market to children.
21.2. If you are under 18, you may use our website only with consent from a parent or guardian
21.4. We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
21.5. Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.
- Encryption of data sent between us
22.1. We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
22.2. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
- How you can complain
23.2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
23.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/ or Data Protection Authority of relevant country.
- Your Rights
24.1. You are entitled to view, amend, or delete the personal information/data that we hold. You have the following rights:
24.1.1. the right to ask what personal data that we hold about you at any time;
24.1.2. the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about; and
24.1.3. (as set out above) the right to opt out of any marketing communications that we may send you or delete the personal information/data entirely.
24.1.4. the right to object to the processing of your information, and
24.1.5. the right to lodge a complaint with the UK Information Commissioner’s Office or Data Protection Authority of relevant country.
- Retention period for personal data
25.1. Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us :
25.1.1. To provide you with the services you have requested;
25.1.2. To comply with other law, including for the period demanded by our tax authorities;
25.1.3. To support a claim or defense in court.
- Compliance with the law
26.2. However, ultimately it is your choice as to whether you wish to use our website.
27.1. We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.