Privacy Policy
Your privacy is of paramount importance to Vault Partners Services FZCO (hereinafter, “Vault”, “we”, “us” or “our”, which terms shall also include our affiliates). This privacy policy (hereinafter, the “Privacy Policy”) applies to the website https://thevaultpartners.com/ (hereinafter, “Website”).
In this Privacy Policy, the term “Personal Data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes personal data as described in Data Protection Legislation (as defined below).
Please read the following carefully. Accepting the terms of this Privacy Policy (by way of ticking a tick box or similar function on the Site) indicates that you have reviewed this Privacy Policy and have agreed to be bound by it. You will be required to expressly accept this Privacy Policy before providing any of your Personal Data to us. If you do not agree to these terms you must leave our Website immediately. If you choose to accept this Privacy Policy, we will keep a record of your acceptance in this regard.
We will handle your Personal Data in accordance with Data Protection Legislation. “Data Protection Legislation” means the Federal Decree Law of the United Arab Emirates No. 45 of 2021 Regarding the Protection of Personal Data and related legislative acts and regulations, as such legislation shall be supplemented, amended, revised or replaced from time to time.
Our servers automatically record information that your browser sends whenever you visit the Website. These server logs may include information such as your web request, Internet Protocol address, browser type and settings, browser language, location data, the address of the web page visited before using the Website, the date and time the Website was used, information about browser configuration and plugins, language preferences and one or more cookies that may uniquely identify your browser. When you send email or other communication to Vault, we may retain those communications in order to process your inquiries, respond to your requests and improve our service (any Personal Data that we collect from you for these purposes is hereinafter referred to together as “Your Data”). Vault is a Controller (as defined in Data Protection Legislation) in respect of Your Data.
This Privacy Policy sets out the basis on which Your Data will be processed by us. We may use Your Data on any one or more of the following legal bases: (i) to perform a contract with you; (ii) for the establishment, exercise or defence of legal claims or proceedings; (iii) to comply with legal and regulatory obligations; (iv) for legitimate business purposes in providing the service to you (in which case, our legitimate interests will not override your fundamental privacy rights); and/or (v) where you have given us your express consent.
When you are a controller in respect of the Personal Data of other data subjects, then you must comply with all of your Controller obligations under Data Protection Legislation. When you are a Controller, we and you act as independent (and not joint Controllers in respect of Your Data.
INFORMATION WE GATHER FROM YOU
We fully respect your right to privacy in relation to your interactions with the Website and with Vault and endeavour to be transparent in our dealings with you as to what information we will collect and how we will use your information. Also, we only collect and use individual’s information where we are legally entitled to do so.
We endeavour to keep Your Data accurate and up-to-date. As such, you must tell us about any changes to such information that you are aware of as soon as possible. You can change your stated interests in respect of whether or not you wish to receive direct marketing from us by clicking ‘unsubscribe’ on any direct marketing electronic communication which you receive from us. If you are aged 18 or under, please get your parent/guardian’s permission before you provide Your Data to us/use the Website.
WHY WE COLLECT/HAVE ACCESS TO YOUR INFORMATION
We may collect information from you as necessary in the course of providing our service. We may collect your personal information while monitoring our technology tools and services, including our Website and email communications sent to and from us. We gather information about you when you provide it to us, or interact with us directly. We may collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date and verifying details using publically available sources. We use that information: (i) to provide and improve our Website, including auditing and monitoring its use; (ii) to provide and improve our service to you and other users; (iii) to provide information requested by you; (iv) to send you update, publications and details of events; (v) to manage and administer our relationship with you; and (vi) to fulfil our legal, regulatory and risk management obligations.
Where we wish to use Your Data in any other way, we will ensure that we notify you and get your consent first. You will be given the opportunity to withhold or withdraw your consent for the use of Your Data for purposes other than those listed in this Privacy Policy.
We may use third parties such as Google Analytics to collect user information, including through the use of cookies (flash and non-flash) and web beacons. They help us improve our service and to deliver many of the functions that make your browser experience more user friendly.
ARE THERE CASES WHERE WE MAY USE YOUR INFORMATION TO CONTACT YOU
We may contact you:
- for administration reasons related to the Website and/or our service;
- to provide you with information about our service, activities or online content, including sending e-newsletters or similar correspondence and updates or responding to any contact you have made with us, e.g. on our Website, by email or via the ‘How To Contact Us’ facility referred to below;
- to invite you to participate in surveys about our services (participation is always voluntary).
RIGHT OF ACCESS TO PERSONAL DATA RELATING TO YOU
You may ask to see what Personal Data we hold about you and be provided with:
- a summary of such Personal Data and the categories of Personal Data held;
- details of the purpose for which it is being or is to be processed;
- details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
- details of the period for which it is held or the criteria we use to determine how long it is held;
- details of your rights, including the rights to rectification, erasure, restriction or objection to the processing;
- any information available about the source of that data;
- whether we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling;
- where your Personal Data are transferred out of UAE, what safeguards are in place.
Details in respect of the above points are all set out in this Privacy Policy; however, if you need further clarification, please contact us (see ‘How To Contact Us’ below).
Requests for your Personal Data must be made to us (see ‘How To Contact Us’ below) specifying what Personal Data you need access to, and a copy of such request may be kept by us for our legitimate purposes in managing the Service. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which we are not obliged to disclose to you, which include Personal Data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations. We are also entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the Personal Date requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
RIGHT TO UPDATE YOUR PERSONAL DATA OR CORRECT ANY MISTAKES IN YOUR PERSONAL DATA
You can require us to correct any mistakes in your Personal Data which we hold free of charge. If you would like to do this, please:
- email or write to us (see ‘How can you contact us’ below);
- let us have enough information to identify you (e.g. name, registration details);
- let us know the information that is incorrect and what it should be replaced with.
If we are required to update your Personal Data, we will inform recipients to whom that Personal Data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the Personal Data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How To Contact Us’ below).
RIGHT TO ASK US TO STOP CONTACTING YOU WITH DIRECT MARKETING
We have a legitimate interest to send you electronic communications in connection with the Website and related matters (which may include but shall not be limited to newsletters, announcement of new features etc.). We may also ask you for your consent to send you direct marketing from time to time. We may also ask you different questions for different services, including competitions. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
- email or write to us (see ‘How can you contact us’ below). You can also click on the ‘unsubscribe’ button at the bottom of the electronic communication. It may take up to 15 days for this to take place;
- let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
We will provide you with information on action taken on a request to stop direct marketing – this may be in the form of a response email confirming that you have ‘unsubscribed’. Unsubscribing from direct marketing does not unsubscribe you from essential electronic communications in respect of the administration of Your Account.
RIGHT TO RESTRICT OR PREVENT PROCESSING OF PERSONAL DATA
In accordance with Data Processing Legislation, you may request that we stop processing your Personal Data temporarily if:
- you do not think that your Personal Data is accurate (but we will start processing again once we have checked and confirmed that it is accurate);
- the processing is unlawful but you do not want us to erase your Personal Data;
- we no longer need the Personal Data for our processing;
- you have objected to processing because you believe that your interests should override the basis upon which we process your Personal Data.
If you exercise your right to restrict us from processing your Personal Data, we will continue to process the Personal Data if:
- you consent to such processing;
- the processing is necessary for the exercise or defence of legal claims;
- the processing is necessary for the protection of the rights of other individuals or legal persons;
- the processing is necessary for public interest reasons.
RIGHT TO ERASURE
In accordance with Data Protection Legislation, you can ask us (please see ‘How To Contact Us’ below) to erase your Personal Data where:
- you do not believe that we need your Personal Data in order to process it for the purposes set out in this Privacy Policy;
- if you had given us consent to process your Personal Data, you withdraw that consent and we cannot otherwise legally process your Personal Data;
- you object to our processing and we do not have any legal basis for continuing to process your Personal Data;
- your Personal Data has been processed unlawfully or have not been erased when it should have been;
- the Personal Data have to be erased to comply with law.
We may continue to process your Personal Data in certain circumstances in accordance with Data Protection Legislation (i.e. where we have a legal justification to continue to hold such Personal Data, such as it being within our legitimate business interest to do so (e.g. retaining evidence of billing information etc.). Where you have requested the erasure of your Personal Data, we will inform recipients to whom that Personal Data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
RIGHT TO COMPLAIN
If you do not think that we have processed your Personal Data in accordance with this Privacy Policy, please contact us in the first instance. If you are not satisfied, you can complain to the UAE Data Office or exercise any of your other rights pursuant to Data Protection Legislation.
WITHDRAWAL OF CONSENT
If you no longer consent to our processing of Your Data (in respect of any matter referred to in this Privacy Policy as requiring your consent), you may request that we cease such processing by contacting us via the ‘How To Contact Us’ facility referred to below. Please note that if you withdraw your consent to such processing, it may not be possible for us to provide all/part of the service to you.
WHO WE SHARE YOUR INFORMATION WITH
Vault will not share Your Data without your consent or unless required by law (except as set out in this Privacy Policy). If Vault becomes involved in a merger, acquisition, or any form of sale of some of all of its assets, Your Data will not be transferred to any third party unless there are adequate safeguards in place with the recipient in respect of the security of Your Data.
We restrict access to Your Data to employees, contractors, and agents who need such access in order to operate, develop, or improve our service and the Website. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/or criminal prosecution, if they fail to meet these obligations. We may also share Your Data with our third party suppliers who assist us in the provision of our service and the Website.
Your Data may be transferred to, stored at, or accessed from a destination outside UAE for the purposes of us providing the Website and our service. It may also be processed by staff operating outside UAE who work for us, another corporate entity within our group, or any of our suppliers. By submitting Your Data, you explicitly consent to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your Data is treated securely and in accordance with this Privacy Policy. The safeguards in place with regard to the transfer of Your Data outside of UAE to third parties shall include (but shall not be limited to) the entry by us into appropriate contracts with all transferees of such data.
All information you provide to us is stored on our (or contracted third party) secure servers.
THIRD PARTY WEBSITES
This Privacy Policy applies to websites and services that are owned and operated by Vault. We do not exercise control over the sites/applications that may be linked from the Website. These other sites/applications may place their own cookies or other files on your computer, collect data or solicit personal information from you. You acknowledge that the Website that we provide may enable or assist you to access the website content of, correspond with, and purchase goods and services from, third parties via third-party websites and that you do so solely at your own risk. We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of your Personal Data. We do not endorse or approve any third-party website nor the content of any of the third-party website made available via the Website. We encourage you to carefully familiarize yourself with the terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.
OFFENSIVE CONTENT
If Your Data contains any material which may reasonably be deemed to be offensive, inappropriate or objectionable or otherwise engage in any disruptive behaviour in relation to the Website or our services, we may remove such content and/or suspend the use of the Website. We may also remove any such material from any of our social media pages.
Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including Data Protection Legislation.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION
We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to Your Data to employees, contractors and agents who need to know Your Data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. However, our Website may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of Your Data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Your Data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your Data, we cannot guarantee the security of any data transmitted to us and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. To the extent permitted by law, we are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that our services may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of Your Data arising from such risks.
BREACH REPORTING
We will notify serious data breaches in respect of Your Data to the UAE Data Office and keep the records as required under the Data Protection Legislation.
RETENTION OF PERSONAL DATA
Your Data will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance. This may include retaining Your Data as necessary to administer our services, comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve the Website and our services.
Where we retain information for the Website and service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of the Website and our service, not to specifically analyze personal characteristics about you.
AMENDMENTS TO PRIVACY POLICY
Vault may change its Privacy Policy from time to time and at Vault’s sole discretion. The date of the most recent revisions will appear on the top of this Privacy Policy. If you do not agree to these changes, please do not continue to use the Website to submit Your Data. If material changes are made to the Privacy Policy, we will notify you by placing a prominent notice on our Website or by sending you a notification in relation to this. We will not process Your Data in a manner not contemplated by this Privacy Policy without your consent.
HOW TO CONTACT US
If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be made in writing by email to info@thevaultpartners.com
