ConvertingTEAM

PRIVACY POLICY

Upon full registration at web portal convertingteam.com a partner or an advertiser (hereinafter the “User”) voluntarily grants its personal data to GingerbreAds FZE, reg. no. 9868, with its registered office at United Arab Emirates, UAQ Free Trade Zone, Al Shmookh Business Center M 1003 (hereinafter the “Controller”), that is the operator of the above web portal. The User may grant its personal data to the Controller by other means.

The Controller, as a controller of personal data, will process User’s personal data upon conditions stated below, in accordance with effective legal regulation applicable on the processing of the personal data of the User, especially but not exclusively with the Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data of United Arab Emirates (hereinafter the “Regulation”).

1. Purpose and legal basis for processing of personal data

User’s personal data will be processed for following purposes:

  1. 1. Conclusion of an agreement between the Controller and the User in accordance with respective general terms and conditions, upon which the Controller enables the User to use software solution (network) operated by the Controller (hereinafter the “Agreement”).
  2. 2. Performance of the Agreement.
  3. 3. Protection of the Controller’s rights arising from the Agreement.
  4. 4. Direct marketing via commercial communication related to products or services of the Controller.
  5. 5. Fulfilment of the Controller’s legal obligations related to personal data processing (especially possible co-operation with the respective public authorities).
  6. 6. Dealing with User’s applications, proposals or complaints.

The legal basis for processing of User’s personal data for purposes presented in numbers 1. and 2. is performance of an Agreement to which the User is party or taking steps at the request of the data subject prior to entering into an Agreement.

The legal basis for processing of User’s personal data for purposes presented in number 3. is Controller’s legitimate interests to protect its rights.

The legal basis for processing of User’s personal data for purposes presented in number 4. is Controller’s legitimate interests to market its products and/or services to its customers.

The legal basis for processing of User’s personal data for purposes presented in numbers 5. and 6. is a fulfilment of legal obligations to which the Controller is subject.

2. Scope and period of processing of personal data

For a purpose of conclusion and performance of the Agreement, as well as for a purpose of fulfilment of the Controller’s legal obligations related to personal data processing, the Controller processes User’s personal data filled in the registration form and/or given to the Controller by other means, within the following scope: name and surname of the User's contact person, User's name, address of the User's registered office, User's telephone number, User's e-mail address, User's Skype identifier and also, as appropriate, User's bank account number, User's PayPal account identifier, User's Skrill account or other account identifier, or other personal data given to the Controller, that are usable for purposes stated in the Privacy Policy.

For a purpose of protection of the Controller’s rights arising from the Agreement, the Controller processes name and surname of the User's contact person, User's name, address of the User's registered office, User's bank account number, User's PayPal account identifier, User's Skrill account or other account identifier, or other personal data given to the Controller, that are usable for this purpose.

For a purpose of a direct marketing via commercial communication related to products or services of the Controller, the Controller processes User’s (and its contact person’s) e-mail address and its name and surname.

For a purpose of dealing with User’s applications, proposals or complaints, the Controller processes User’s personal data given in respective application, proposal or complaint.

User’s personal data will be processed for a period, that is necessary for fulfilment of respective purpose of its processing:

  1. For purposes of conclusion and performance of the Agreement, the Controller processes personal data for a period of duration of the Agreement and for 3 years from termination of the Agreement.
  2. For a purpose of protection of the Controller’s rights arising from the Agreement, the Controller processes personal data for a period necessary for the protection of Controller’s rights and in accordance with respective laws.
  3. For a purpose of a direct marketing via commercial communication related to products or services of the Controller, the Controller processes personal data until the Controller receives an objection or other type of disagreement with further processing for such purpose of the processing, and then for 1 month, that is a period needed to carry out relevant technical measures to delete respective personal data from Controller’s internal system.
  4. For a purpose of fulfilment of the Controller’s legal obligations related to personal data processing, the Controller processes personal data for a period necessary to fulfil respective legal obligations related to personal data processing.
  5. For a purpose of dealing with User’s applications, proposals or complaints, the Controller processes personal data for an appropriate period necessary to deal with them.

3. Source of personal data

The Controller mainly obtains personal data directly from the User, mainly by a registration form on its web portal. However, the Controller may obtain personal data even not from the User, mainly from Controller’s business partners. Even in such situation, the same personal data processing rules apply.

The Controller always considers received personal data to be of a true and current nature. Should personal data become outdated, the User shall update its personal data as soon as possible by a notice given to the Controller, to an e-mail address stated below.

4. Manner of processing of personal data, protection of personal data, recipients of personal data

Personal data are processed by the Controller. The Controller may authorize processor(s) to process such personal data. If the Controller does so, it will provide User’s personal data to authorized processor(s), that are one of categories of recipients of personal data. For now, processors are: IT service providers, cloud service providers.

Recipients of personal data may also be respective public authorities, if such provision of data is stipulated by law.

All Controller’s obligations on data processing are always binding to processor(s) authorized by the Controller. The Controller, as well as authorized processor(s), will not publish User’s personal data, unless agreed otherwise.

The Controller processes personal data automatically.

The Controller implemented appropriate technical and organisational measures to ensure protection of processed personal data to avoid a security breach leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, as well as other type of abuse.

5. User’s rights of personal data subject

The User, as a personal data subject, is entitled to right of access to personal data, right to rectification, right to erasure of personal data and other rights arising from the Regulation. The User may learn more about their rights of personal data subject by reaching out the Controller via e-mail address listed below.

The Controller deals with all applied User’s rights for free. However, if User’s application to apply the right is unreasonable or inappropriate, particularly because such application is repeated without a fair reason, the Controller shall be entitled to ask the User for a compensation (with regards to administrative costs related to provision of requested information or communication, or to taking requested acts); or the Controller shall be entitled to refuse User’s application.

Should the User object to processing of its personal data for a purpose of direct marketing, the Controller shall be obliged to satisfy such application.

6. Controller’s contact information

The User can contact the Controller at the following e-mail address: finance@convertingteam.com

This Privacy Policy is valid and effective as of 15th January 2024.