Privacy Policy

Introduction

Alfii Software Services DMCC having its registered office at DD-14-124-027, 14th Floor, Al Khatem Tower Wework Hub71, Abu Dhabi Global Market Square, Al Maryah Island, Abu Dhabi, United Arab Emirates collectively “Alfii”, “we”, “us”, or “our”), owns and operates alfii.co and the Alfii application (collectively, the "Platform") . We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we process your personal data when you visit the Platform (regardless of where you visit it from) and tell you about your privacy rights according to the applicable laws. Please read this Privacy Policy carefully.

Consent

Each time you visit the Platform or use the services provided on the Platform, you consent to the collection, use, disclosure, and processing of personal data in accordance with this Privacy Policy.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a PDF version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

  1. 1. IMPORTANT INFORMATION AND WHO WE ARE.
  2. 2. THE DATA WE COLLECT ABOUT YOU
  3. 3. HOW IS YOUR PERSONAL DATA COLLECTED?
  4. 4. HOW WE USE YOUR PERSONAL DATA.
  5. 5. DISCLOSURES OF YOUR PERSONAL DATA.
  6. 6. INTERNATIONAL TRANSFERS.
  7. 7. DATA SECURITY.
  8. 8. DATA RETENTION.
  9. 9. YOUR LEGAL RIGHTS.
  10. 10. GLOSSARY.

1. Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Alfii collects and processes your personal data through your use of the service, including any data you may provide through this website when you purchase our service. This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with our Terms of Use and any cookie policy or any other policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them. 

Controller

Alfii is the controller and responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. 

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review. This version was last updated on 8th of February 2023. 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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. 
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.  
  • Usage Data includes information about how you use our website, products and services. 
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. For the purpose of this clause, Aggregated Data shall mean data that could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or to provide high level analytics and best practice recommendations, as well as product research for us in order to improve your experience.  However, in the event the Aggregated Data is combined or connected with your personal data so that it can directly or indirectly identify you, the combined data will be treated as personal data which will be used in accordance with this Privacy Policy.

We do not collect any special categories of Personal Data about you which 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. Nor do we collect any information about criminal convictions and offenses.

If you fail to provide personal data

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 for example, to provide you with services. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. 

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our services;
  • create an account on our platform;
  • subscribe to our service or publications; 
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us. 

Automated technologies or interactions. As you interact with our service, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. You have the right to object to this type of collection by contacting us on the details provided below. 

Third parties or publicly available sources. From time to time, We may receive personal data about you from various third parties and public sources.

4. How we use your personal data

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:

  • Where we have your consent;
  • Where we need to perform the contract, we are about to enter into or have entered into with you;     
  • Where we need to comply with a legal obligation.
  • You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

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. 

Purpose/Activity

Type of data

Lawful basis for processing

To register you as a new customer

(a) Identity 
(b) Contact

Performance of a contract with you

To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity 
(b) Contact 
(c) Financial 
(d) Transaction 
(e) Marketing and Communications

Performance of a contract with you 

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

(a) Identity 
(b) Contact 
(c) Profile 
(d) Marketing and Communications

(a) Performance of a contract with you 
(b) Necessary to comply with a legal obligation

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity 
(b) Contact 
(c) Profile 
(d) Usage 
(e) Marketing and Communications

Performance of a contract with you 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  

(a) Identity
(b) Contact
(c) Technical

Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical 
(b) Usage 

Performance of a contract with you 

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile 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 products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have the right to opt out of receiving that marketing at any time by contacting us.

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform website may become inaccessible or not function properly. For more information about the cookies we use, please see Alfii Cookie Policy (coming soon).

Change of purpose 

We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for another reason, we will obtain your consent. 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

We may share your personal data with Third Parties for the purposes set out in the table above..

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.

International transfers

We share your personal data within Alfii. This will involve transferring your data outside the UAE.

Many of our external third parties are based outside the UAE so their processing of your personal data will involve a transfer of data outside the UAE. 

Whenever we transfer your personal data out of the UAE, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  •  Where we use certain service providers, we may use specific contracts approved for use in the UAE which give personal data the same protection it has in the UAE. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UAE.

7. Data security

We have put in place appropriate technical and organizational security and safeguard measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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. 

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.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Platform and any transmission is at your own risk.

8. Data retention

How long will you use my personal data for?

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. When it is no longer necessary to retain your personal data, we will delete or anonymise it.

In some circumstances you can ask us to delete your data; see your legal rights below for further information.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please refer to Section 10.3 (YOUR LEGAL RIGHTS) in this Policy.

10. Glossary

10.1. LAWFUL BASIS

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.

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.THIRD PARTIES

Third Parties includes without limitation:

  • Other companies in the Alfii group of companies, from time to time, acting as joint controllers or processors and who are based UAE and provide IT and system administration services and undertake leadership reporting. 
  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy services.
  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

10.3. YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

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.

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. 

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 and automated processing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

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: 

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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. 
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

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. 

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.

11. Contact details

If you have any questions about this policy or our privacy practices, or wish to contact us concerning any matter relating to your legal rights and your personal data, you may send an email to our data privacy manager on below the email address and we will try our best to resolve it. 

hello@alfii.co

You have the right to make a complaint at any time to the UAE Data Office, the UAE regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the Data Office, so please contact us in the first instance.