👀Privacy Policy
1. General provisions
This privacy policy (hereinafter referred to as "Privacy Policy") provides you with the necessary information on how the company A T C COMPUTER SYSTEMS & COMMUNICATION EQUIPMENT SOFTWARE DESIGN CO. L.L.C Register No. 1830111 Registered office: AL BUDOOR BUILDING 386-0, NAIF, DUBAI - UAE (hereinafter referred to as the “Company” or “we” or “us”) as a controller of the personal data, receives, stores and further processes your personal data and how we protect such personal data.
Personal data is any information relating to an identified or identifiable person, therefore you, if you are our client, who is a natural person or our client´s employee or person who acts on behalf of our client (hereinafter referred to as “you”).
This Privacy Policy explains and informs you on (i) how we, collect, and process your personal data (ii) your rights and the means by which you may apply them.
We recommend you to get fully acquaint with this Privacy Policy. By using our services and by providing us with your personal data you confirm, that you have been informed on processing of your personal data as stated in this Privacy Policy.
This Privacy Policy provides you the information that is in compliance with Regulation.
2. Terms and definitions used in the Privacy Policy
personal data - means any information relating to an identified or identifiable natural person an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, surname, date of birth, location data, email;
sensitive personal data - means the specific categories of personal data that are personal data that are revealing racial or ethnic origin, political opinions, religious /belief/ or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation, and data on criminal activities;
processing of personal data - means any operation or set of operations which is performed on your personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
controller - means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
processor - means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
purpose- reason why controller is processing your personal data;
legitimate interest – purpose of controller, processor or other entity that are determined by Union or Member Stater law;
cookies – A cookie is a small piece of data (text file) that a website –when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. The cookies we use may be divided as those used by us as first party cookies (technical cookies) which are necessary to provide you with functionality of the Site and third party cookies – which are cookies from different domain (for advertising and marketing purposes).
recipient – the person that receives the personal data
third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
consent - freely given, specific, informed and unambiguous indication of yours wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to you.
3. Categories of the personal data processed by us
1. Basic personal data
Basic personal data are the data that are necessary for conclusion and performance of the contract, in particular:
Name;
Surname;
Academic titles;
Permanent address;
Date of birth;
Payment information details
2. Contact personal data
Contact personal data are following:
E-mail;
Telephone number.
3. Cookies
The source of personal data on website users of the Company are (may be) to the significantly restricted extent also “cookies” acquired by the Company in connection with activities of website visitors of the Company’s website – You will find more detailed information in our Cookies Policy.
4. Purposes, method and period of time of processing the personal data
1. Performance of the contract
We are processing your personal data for the purpose of fulfilling the contract on provision of services which is concluded between you and the Company. The legal basis is the fulfilment of the contract or legitimate interest. We process your personal data primarily during the potential complaint process, or it may be part of your selected player name.
2. Compliance with legal obligations
We are processing your personal data for the purpose of complying with a legal obligations (in particular obligations under accounting and tax laws, i.e. transfers of personal data to tax and revenue authorities and, where appropriate, to other public authorities in compliance with applicable laws; due keeping of the legal file and tax advisor’s file including e-mail communication, lists of contacts and the services provided).
Personal data for this purpose are being processed for the period stipulated by applicable legal regulation.
3. Performance of the contract
We are processing your personal data for the purpose of fulfilling the contract on provision of services which is concluded between you and the Company. The legal basis is the fulfilment of the contract or legitimate interest. We process your personal data primarily during the potential complaint process, or it may be part of your selected player name.
4. Compliance with legal obligations
We are processing your personal data for the purpose of complying with a legal obligations (in particular obligations under accounting and tax laws, i.e. transfers of personal data to tax and revenue authorities and, where appropriate, to other public authorities in compliance with applicable laws; due keeping of the legal file and tax advisor’s file including e-mail communication, lists of contacts and the services provided).
Personal data for this purpose are being processed for the period stipulated by applicable legal regulation.
5. Legitimate interest
In case you would not have fulfilled your obligations toward us or you would have caused us a damage or harm, we may further store your personal data on the basis of the legitimate interest consisting of recovery of our claims against you and/or to protect and enforce our claims. For this purpose we can process your personal for the period of time corresponding to the statutory limitation period.
5. Transfer of the personal data to third persons
1. We may transfer your personal data we collect to third persons to ensure the performance of our obligation, including administration or IT support, organisation and storage of the personal data etc. These subjects are in the position of processors of your personal data.
2. Beneficiaries of the collected personal data are in particular the following subjects:
with our cooperating providers of legal and tax services;
with our suppliers (contractors) of IT services, systems and applications, who may have in specific cases access to your personal data, including the provider of our cloud services where we store all of our data;
with our external providers of accounting and tax services that are necessary for fulfilling of our legal obligations; and
with our external providers of legal services that are necessary for enforcement of our claims and for protection of our legal entitlements.
(hereinafter referred to as “Processors”)
1. We provide you with guarantee that we have concluded a contract on processing of personal data with the Processors, which ensure the same level of safety for your personal data as those described in this Privacy Policy.
2. We, including the Processors, are obliged to keep all the personal data confidential. The exemption is the duty to report your personal data to the designated public authorities and other entities who are entitled to request the personal data by the law (i.e. Police, Tax authority etc.).
6. Security of your personal data
We have introduced to our system such necessary technical and organisational measures of internal control and processes of safety of the information that are in compliance with best practice corresponding to the potential risk to you. At the same time we take into consideration the perspective of the future technological progress in order to protect your personal data from unauthorised disclosure, access or its loss. These measures include, but are not limited to, employees’ data protection training, regular backups of the data, data recovery procedure, and mechanism of responsibility for an infringement of protected data, software and hardware protection.
7. Your rights as a subject of personal data
1. If you exercise your right in accordance with this Sec. 7 of the Privacy Policy or in accordance with other applicable legal provision, we will inform on the adopted measure about your personal data every Processor who is processing such data, if such communication to the Processor is possible and/or does not require unreasonable effort.
2. If you wish to exercise your rights or to receive the relevant information, contact us via one of our Contact details. When you contact us, we have to ask you to provide us with your identification information or other personal data which you have provided us earlier. The provision of such information is necessary for the verification if it is you who has actually sent such request. We will provide you with answer no later than one month after receiving such request, whereby we retain the right to extend in by two months.
3. Your rights. In accordance with the applicable law you may require an access to the personal data, which we, as a controller of personal data, process, the right for rectification, erasure or transferability, right to lodge a complaint and right to require the restriction of the processing. At any time you may withdraw your consent on processing of personal data.
4. Rectification of your personal data. In accordance with the law you have the right for the rectification of the personal data that you share with us. If you have a request for rectification of your personal data, you may contact us with a request on via one of our Contact details. We accept measures to ensure that you have your personal data up-to-date and correct. Anytime you may contact us with a request if we still process your personal data.
5. Erasure of your personal data. Anytime you may provide us with a request for erasure of the personal data. After you contact us with such request we will erase all your personal data from our databases without undue delay, unless we process some of your personal data for the purpose of performance of the contract, because of our legal obligation or if it is in our legitimate interest. Further we, as well as all the Processors, erase your personal data if you withdraw your consent on processing of personal data or if it is required by the law.
6. Withdrawal of the consent on processing of personal data. Anytime you may withdraw the consent on processing of personal data that you granted us without giving us any reason. If you want to withdraw your consent let us know via one of our Contact details and we will erase your personal data in accordance with the Sec. 8.5 of this Privacy Policy. Please take into account that the withdrawal of the consent does not affect the lawfulness of the previous processing on the basis of given consent.
7. Access and transferability of your personal data. You have a right to receive your personal data you have provided to us. If you require, we can transfer all or only part of your personal data (processed on the basis of the contract or consent) directly to a third person (other controller of personal data), whom you mention in your request for the transfer of the personal data, if such request will not have negative effect on the rights and freedoms of other persons and will be technically feasible.
8. Restriction of the processing. If you request us to restrict the processing of your personal data, especially in cases when you doubt the accuracy, lawfulness or our need to process your personal data, we will restrict the processing of your personal data to the necessary minimum (processing for assessment, enforcement or defence of our legal claims or because of the protection of right of another natural or legal person or from other reasons). However if the restriction of the processing is cancelled and we will continue in processing of your personal data, we will give you a notice about this without undue delay.
8. Up-dating of this Privacy Policy
1. We continuously up-date this Privacy Policy. Any change to this Privacy Policy is effective after it is made public for you.
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