PRIVACY POLICY
1.General Information
At Greenway Consulting, we respect your privacy and are committed to protecting your personal information in accordance with this Privacy Policy (the "Policy"). This Policy outlines the types of personal data we collect on the website https://www.gwc.ae/en (the "Website" or "Service"), as well as on any related products and services (collectively referred to as "Services"). It explains how we use this data and how you can modify, export, or delete your personal information.
2.Privacy Agreement
This Policy is a legally binding agreement between you (the "User", "you", or "your") and Greenway Consulting ("Greenway Consulting", "we", "us", or "our"). If you are entering into this agreement on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind such entity to this agreement. In this case, the terms "User", "you", or "your" will refer to that entity. If you do not have such authority or disagree with the terms of this agreement, you must not accept this agreement and are not authorized to access or use the Website and Services. By visiting and using the Website and Services, you confirm that you have read, understood, and agreed to the terms of this Policy. This Policy applies only to information we process while you are using our Website. It does not cover the practices of companies we do not own or control or individuals we do not employ or manage.
3.Automatic Information Collection
When you access the Website, our servers automatically record information sent by your browser. This data may include details such as your IP address, browser type and version, operating system type and version, language preferences, the website you visited before coming to our Website, the pages you visit, the time spent on those pages, the information you search for, access times and dates, and other statistics. Automatically collected information is used solely to identify potential abuse and to compile statistical data on website usage and traffic. This data is aggregated in a way that does not identify any individual user.
4.Personal Data Storage
You can access and use the Website and Services without revealing your identity or providing any personal information. However, if you wish to use certain features offered on the Website, you may be asked to provide specific personal data (such as your name and email address). We collect and store any information you knowingly provide, such as when you make a purchase or fill out a form on the Website. This information may include:
5. Children's Privacy
We understand the importance of protecting children's privacy. We do not knowingly collect personal data from individuals under the age of 18. If you are under 18, please do not submit any personal information through our Website or Services. If you believe that a child under the age of 18 has provided us with their personal information through the Website or Services, please contact us, and we will take steps to remove that information. We encourage parents and guardians to monitor their children's internet use and ensure that this Policy is followed by educating their children to never provide personal information without permission. We also ask that parents and guardians take necessary precautions to prevent their children from sharing personal data online without consent.
6. Use and Processing of Collected Information
We act as both a data controller and a data processor in accordance with the General Data Protection Regulation (GDPR) when handling personal data, unless we have entered into a data processing agreement with you where you act as the data controller, and we act as the processor. Our role may differ depending on the specific context of the personal data involved. We act as the data controller when we request personal data from you to facilitate your access and use of the Website and Services. As a data controller, we determine the purposes and means of processing your personal data and comply with the obligations of data controllers as set forth by GDPR. When a User provides personal data on the Website or Services, we act as the data processor. We do not own, control, or make decisions about the personal data provided and process it only as instructed. In such cases, the User acts as the data controller under GDPR.
We may collect and use personal data to make the Website and Services available to you or to meet legal requirements. If you choose not to provide the requested information, we may not be able to deliver the products or services you have requested. Any information we collect from you may be used for the following purposes:
1.You have given consent for one or more specific purposes, except where processing is carried out under European data protection law.
2.The provision of information is necessary for fulfilling an agreement with you and/or any pre-contractual obligations.
3.Processing is necessary for compliance with legal obligations to which you are subject.
4.Processing is related to a task carried out in the public interest or in the exercise of official authority vested in us.
5.Processing is necessary for the purposes of legitimate interests pursued by us or by a third party.
We rely on the following legal bases under GDPR for collecting and processing your personal data:
7. Payment Processing
If our Services require payment, you may need to provide credit card information or other payment account details, which will be used solely to process the payment. We use third-party payment systems ("Payment Systems") to securely process your payment information. These Payment Systems comply with PCI-DSS security standards, governed by the PCI Security Standards Council, a joint effort by brands such as Visa, MasterCard, American Express, and Discover. Sensitive information is encrypted and transmitted securely using SSL, and the Website and Services meet strict security standards to ensure a safe environment for our Users. We will share payment information with Payment Systems only to the extent necessary for processing your payments, issuing refunds, and handling any disputes or inquiries related to payments and refunds. Please be aware that Payment Systems may collect some personal information from you (such as your email address, billing address, credit card details, or bank account number) and use this data to complete the payment process. The use of your personal data is governed by the privacy policies of the respective Payment Systems, which may or may not provide the same level of privacy protection as described in this Policy. We recommend reviewing the privacy policies of the Payment Systems.
8. Information Disclosure
Depending on the services requested or as necessary to complete a transaction or provide a service, we may share your information with affiliated companies, subsidiaries, suppliers, or agents acting on our behalf ("Service Providers"), who operate as data processors to help run the Website and Services. Their privacy policies are aligned with ours, and the information they receive is used only for purposes stated in this Policy. Personal data collected by us will not be sold or shared with third parties. Service Providers are not authorized to use or disclose your information for their own marketing or other purposes unless it is necessary to provide services on our behalf or comply with legal requirements. Service Providers receive only the information they need to perform their designated tasks, and we require that our partners and Service Providers adequately protect the confidentiality and security of Users' personal data. Where required or permitted by law, we may also disclose your personal data globally to regulatory, financial, law enforcement, judicial, governmental, or public authorities to ensure compliance with legal obligations or protect our rights and interests or the rights and interests of others. If we undergo a business reorganization, such as a merger, acquisition, or sale of all or part of our assets, your personal data may be among the transferred assets.
9. Data Retention
We will retain and use your personal data for as long as necessary to fulfill our legal obligations, enforce our agreements, resolve disputes, and where longer retention is not required or permitted by law. We may continue to use any information derived from your personal data after you update or delete it, but in a way that does not personally identify you. Once the retention period expires, your personal data will be deleted. Therefore, your right to access, delete, correct, or transfer data cannot be exercised after the retention period has ended.
10. Data Transfers
Depending on your location, data transfers may involve transmitting and storing your information in a different country, including the UAE. Transfers of your personal data to countries outside the European Union will only occur with your explicit consent or under the conditions outlined in the GDPR, and always with your best interests in mind. You have the right to be informed about the legal grounds for transferring your data to a non-EU country or any international organization governed by public international law or created by two or more countries, such as the United Nations, as well as the security measures we have in place to protect your information. If such a transfer occurs, you can learn more by reviewing the relevant sections of this Policy or contacting us using the details provided in the "Contact Us" section.
11. Data Protection Rights under GDPR
If you are a resident of the European Economic Area (EEA), you have certain data protection rights, and we are committed to taking reasonable steps to allow you to access, correct, delete, or limit the use of your personal data. If you wish to know what personal data we hold about you and if you want it removed from our systems, please contact us. In certain circumstances, you have the following rights:
11.1. If your consent is the legal basis for processing your personal data, you can withdraw it at any time. This will not affect the lawfulness of processing based on your consent before its withdrawal.
11.2. You have the right to know if we are processing your personal data, to receive information about certain aspects of the processing, and to obtain a copy of your personal data that is being processed.
11.3. You have the right to verify the accuracy of your data and request that it be updated or corrected. You also have the right to request that we supplement any incomplete personal data.
11.4. You have the right to object to the processing of your personal data. If you object, we will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms. However, if your personal data is processed for direct marketing purposes, you may object to such processing at any time without providing any justification. To find out whether we process personal data for direct marketing purposes, please refer to the relevant sections of this Policy.
11.5. You have the right, in certain circumstances, to restrict the processing of your personal data. These circumstances include: if you contest the accuracy of your personal data and we need to verify it; if the processing is unlawful, but you oppose the deletion of your personal data and request its restricted use instead; if we no longer need your personal data for processing purposes, but you require it for the establishment, exercise, or defense of legal claims; or if you have objected to the processing, pending the verification of whether our legitimate grounds override your own. If processing is restricted, your personal data will only be processed, except for storage, with your consent or for the establishment, exercise, or defense of legal claims, or to protect the rights of another person, or for reasons of important public interest.
11.6. You have the right, in certain circumstances, to request the deletion of your personal data. These circumstances include: when the personal data is no longer necessary for the purposes for which it was collected or otherwise processed; when you withdraw your consent to processing based on consent; when you object to processing under certain applicable data protection laws; when the personal data was unlawfully processed; or when the personal data is processed for direct marketing purposes. However, there are exceptions to the right to deletion, such as when processing is necessary for exercising the right to freedom of expression and information, for compliance with legal obligations, or for the establishment, exercise, or defense of legal claims.
11.7. You have the right to receive your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format, and, where technically feasible, to have it transferred to another data controller without hindrance from us, provided that such transfer does not adversely affect the rights and freedoms of others.
11.8. You have the right to lodge a complaint with the data protection authority in your country regarding our collection and use of your personal data. If you believe that the processing of your personal data violates applicable data protection laws, you have the right to file a complaint with the relevant supervisory authority. The supervisory authority depends on the country in which you reside. This provision applies as long as the personal data is processed by automated means and the processing is based on the User's consent, a contract to which the User is a party, or pre-contractual obligations.
12. Exercising Your Rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must include sufficient information for us to confirm that you are the person you claim to be or that you are authorized to act on behalf of such a person. If we receive your request from an authorized representative, we may request proof that you have authorized the representative or that the representative has valid written authority to submit requests on your behalf.
You must provide enough information to help us understand the request and respond appropriately. We cannot respond to your request or provide you with personal information unless we first verify your identity or authority to make such a request and confirm that the personal information relates to you.
13. Use of Cookies
Our Website and Services use cookies to help personalize your online experience. Cookies are small text files sent by a web server to your browser to track activity on a specific website. These files are stored locally on your device’s hard drive. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are unique to the User's profile and can only be read by the web server in the domain that issued the cookie. We may use cookies to collect, store, and track information for security, personalization, and statistical purposes. Please note that you can choose to accept or decline cookies. Most web browsers automatically accept cookies by default, but you can modify your browser settings to block or delete cookies.
14. Data Analytics
Our Website and Services may use third-party analytics tools that use cookies, web beacons, or other similar technologies to collect information as part of our analytics efforts to help us understand how Users engage with our Website and Services. The information collected is used to compile statistical reports on User activity, including how often and how long Users visit our Website and Services. We use the information gathered from these analytics tools to monitor and improve the performance of our Website and Services. We do not use third-party analytics tools to track or collect any personal information about our Users, and we do not link any statistical information to specific Users.
15. Do Not Track Signals
All major web browsers offer a "Do Not Track" feature that allows websites to notify that you do not want to be tracked. Tracking refers to the collection of personal information from consumers who use or visit a website or online service as they move across different websites over time. However, there is no standard for interpreting or responding to Do Not Track signals. As a result, our Website and Services are not currently configured to respond to Do Not Track signals transmitted by your browser. Nevertheless, as detailed in this Policy, we limit the use and collection of your personal data.
16. Advertising
We may display online advertisements and share non-identifying information about our customers that we or our advertisers collect during your use of the Website and Services. We do not share personal information that would allow advertisers to identify specific individuals. In some cases, we may use this collected non-identifying information to provide targeted advertising to specific audiences. We may also allow third-party companies to help us tailor ads that we believe might interest Users by collecting and using additional data about User activities on the Website. These companies may deliver ads that place cookies and track User behavior on the Website.
17. Social Media Features
Our Website and Services may include social media features such as Facebook and Twitter buttons, "Share" buttons, and others (collectively referred to as "Social Media Features"). These features may collect information such as your IP address and which page you are visiting on our Website, and may place cookies to allow the features to function properly. Social Media Features are either hosted by their respective providers or directly on our Website. Your interactions with these features are governed by the privacy policy of the respective provider.
18. Email Marketing
We offer email newsletters that you may subscribe to voluntarily at any time. We are committed to keeping your email address confidential and will not disclose your email address to third parties except as allowed under the "Use and Processing of Information" section or as required by third-party service providers to send such emails. We will store any email communication in compliance with applicable laws and regulations. In accordance with anti-spam laws, all emails sent from us will clearly state the sender and include information on how to contact them. You can opt out of receiving our newsletters or marketing emails by following the unsubscribe instructions included in those emails or by contacting us directly. However, you will continue to receive essential transactional emails.
19. Push Notifications
We offer push notifications, which you can voluntarily subscribe to at any time. To ensure push notifications reach the correct devices, we use a third-party push notification provider, which relies on a unique device token assigned by your device’s operating system. Although device tokens are accessible, they do not reveal your identity, your device's unique identifier, or your contact information to us or our third-party push notification provider. We store information sent through email in compliance with applicable laws and regulations. If you wish to stop receiving push notifications at any time, simply adjust your device settings accordingly.
20. Affiliate Links
We may engage in affiliate marketing and include affiliate links on the Website and within the Services to offer you relevant or supplementary products and services. When you click on an affiliate link, a cookie will be placed in your browser to track any sales for the purpose of earning a commission.
21. Links to Third-Party Websites
The Website and Services may contain links to third-party websites that are not owned or controlled by us. Please note that we are not responsible for the privacy practices of such other websites or third parties. We recommend that you be aware of when you leave the Website and Services and review the privacy policy of each website that may collect personal data.
22. Data Security
We store the information you provide on computer servers in a controlled and secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and disclosure of personal data under our control. However, no data transmission over the Internet or wireless network can be guaranteed. As a result, while we strive to protect your personal data, you acknowledge that (1) there are security and privacy limitations of the Internet that are beyond our control; (2) the security, integrity, and privacy of any information and data exchanged between you and the Website and Services cannot be guaranteed; and (3) any such information and data may be viewed or altered by a third party during transmission, despite our efforts. The security of personal data also depends in part on the security of the device you use to communicate with us and the security measures you use to protect your login credentials. Please take appropriate measures to protect this information.
23. Data Breach
If we become aware that the security of the Website and Services has been compromised or Users' personal data has been disclosed to unrelated third parties due to external activity, including, but not limited to, security attacks or fraud, we reserve the right to take appropriate measures, including, but not limited to, investigation and reporting, as well as notifying law enforcement authorities and cooperating with them. In the event of a data breach, we will take all necessary measures to notify affected individuals if we believe there is a reasonable risk of harm to the User as a result of the breach or if notification is otherwise required by law. When we do so, we will post a notice on our Website and send you an email.
24. Changes and Amendments
We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also notify you in other ways at our discretion, such as through the contact information you have provided. The updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or any other act specified at that time) will constitute your acceptance of those changes. However, without your consent, we will not use your personal data in a manner that is materially different from what was stated at the time your personal data was collected.
25. Acceptance of this Policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information, you agree to be bound by this Policy. If you do not agree to comply with the terms of this Policy, you are not authorized to access or use the Website and Services.
26. Contacting Us
If you have any questions about the information we hold about you or wish to exercise your rights, you can use the following form to submit your request: Submit a Data Access Request. If you have any other questions, concerns, or complaints regarding this Policy, we encourage you to contact us using the information below: office@gwc.ae We will endeavor to resolve any complaints and disputes and take all necessary measures to ensure you can exercise your rights as quickly as possible and in any case within the timeframes provided by applicable data protection laws.
Last updated on May 6, 2023.
1.General Information
At Greenway Consulting, we respect your privacy and are committed to protecting your personal information in accordance with this Privacy Policy (the "Policy"). This Policy outlines the types of personal data we collect on the website https://www.gwc.ae/en (the "Website" or "Service"), as well as on any related products and services (collectively referred to as "Services"). It explains how we use this data and how you can modify, export, or delete your personal information.
2.Privacy Agreement
This Policy is a legally binding agreement between you (the "User", "you", or "your") and Greenway Consulting ("Greenway Consulting", "we", "us", or "our"). If you are entering into this agreement on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind such entity to this agreement. In this case, the terms "User", "you", or "your" will refer to that entity. If you do not have such authority or disagree with the terms of this agreement, you must not accept this agreement and are not authorized to access or use the Website and Services. By visiting and using the Website and Services, you confirm that you have read, understood, and agreed to the terms of this Policy. This Policy applies only to information we process while you are using our Website. It does not cover the practices of companies we do not own or control or individuals we do not employ or manage.
3.Automatic Information Collection
When you access the Website, our servers automatically record information sent by your browser. This data may include details such as your IP address, browser type and version, operating system type and version, language preferences, the website you visited before coming to our Website, the pages you visit, the time spent on those pages, the information you search for, access times and dates, and other statistics. Automatically collected information is used solely to identify potential abuse and to compile statistical data on website usage and traffic. This data is aggregated in a way that does not identify any individual user.
4.Personal Data Storage
You can access and use the Website and Services without revealing your identity or providing any personal information. However, if you wish to use certain features offered on the Website, you may be asked to provide specific personal data (such as your name and email address). We collect and store any information you knowingly provide, such as when you make a purchase or fill out a form on the Website. This information may include:
- Contact information (such as your email address or phone number)
- Basic personal details (such as your name and country of residence)
- Geolocation data from your device (such as latitude and longitude)
5. Children's Privacy
We understand the importance of protecting children's privacy. We do not knowingly collect personal data from individuals under the age of 18. If you are under 18, please do not submit any personal information through our Website or Services. If you believe that a child under the age of 18 has provided us with their personal information through the Website or Services, please contact us, and we will take steps to remove that information. We encourage parents and guardians to monitor their children's internet use and ensure that this Policy is followed by educating their children to never provide personal information without permission. We also ask that parents and guardians take necessary precautions to prevent their children from sharing personal data online without consent.
6. Use and Processing of Collected Information
We act as both a data controller and a data processor in accordance with the General Data Protection Regulation (GDPR) when handling personal data, unless we have entered into a data processing agreement with you where you act as the data controller, and we act as the processor. Our role may differ depending on the specific context of the personal data involved. We act as the data controller when we request personal data from you to facilitate your access and use of the Website and Services. As a data controller, we determine the purposes and means of processing your personal data and comply with the obligations of data controllers as set forth by GDPR. When a User provides personal data on the Website or Services, we act as the data processor. We do not own, control, or make decisions about the personal data provided and process it only as instructed. In such cases, the User acts as the data controller under GDPR.
We may collect and use personal data to make the Website and Services available to you or to meet legal requirements. If you choose not to provide the requested information, we may not be able to deliver the products or services you have requested. Any information we collect from you may be used for the following purposes:
- Delivering products and services
- Sending administrative information
- Sending marketing and promotional messages
- Providing product and service updates
- Responding to inquiries and offering support
- Requesting user feedback
- Publishing customer reviews
- Providing targeted advertising
- Operating and maintaining the Website and Services
1.You have given consent for one or more specific purposes, except where processing is carried out under European data protection law.
2.The provision of information is necessary for fulfilling an agreement with you and/or any pre-contractual obligations.
3.Processing is necessary for compliance with legal obligations to which you are subject.
4.Processing is related to a task carried out in the public interest or in the exercise of official authority vested in us.
5.Processing is necessary for the purposes of legitimate interests pursued by us or by a third party.
We rely on the following legal bases under GDPR for collecting and processing your personal data:
- User consent
- Legal and regulatory compliance
- Data that is publicly available
7. Payment Processing
If our Services require payment, you may need to provide credit card information or other payment account details, which will be used solely to process the payment. We use third-party payment systems ("Payment Systems") to securely process your payment information. These Payment Systems comply with PCI-DSS security standards, governed by the PCI Security Standards Council, a joint effort by brands such as Visa, MasterCard, American Express, and Discover. Sensitive information is encrypted and transmitted securely using SSL, and the Website and Services meet strict security standards to ensure a safe environment for our Users. We will share payment information with Payment Systems only to the extent necessary for processing your payments, issuing refunds, and handling any disputes or inquiries related to payments and refunds. Please be aware that Payment Systems may collect some personal information from you (such as your email address, billing address, credit card details, or bank account number) and use this data to complete the payment process. The use of your personal data is governed by the privacy policies of the respective Payment Systems, which may or may not provide the same level of privacy protection as described in this Policy. We recommend reviewing the privacy policies of the Payment Systems.
8. Information Disclosure
Depending on the services requested or as necessary to complete a transaction or provide a service, we may share your information with affiliated companies, subsidiaries, suppliers, or agents acting on our behalf ("Service Providers"), who operate as data processors to help run the Website and Services. Their privacy policies are aligned with ours, and the information they receive is used only for purposes stated in this Policy. Personal data collected by us will not be sold or shared with third parties. Service Providers are not authorized to use or disclose your information for their own marketing or other purposes unless it is necessary to provide services on our behalf or comply with legal requirements. Service Providers receive only the information they need to perform their designated tasks, and we require that our partners and Service Providers adequately protect the confidentiality and security of Users' personal data. Where required or permitted by law, we may also disclose your personal data globally to regulatory, financial, law enforcement, judicial, governmental, or public authorities to ensure compliance with legal obligations or protect our rights and interests or the rights and interests of others. If we undergo a business reorganization, such as a merger, acquisition, or sale of all or part of our assets, your personal data may be among the transferred assets.
9. Data Retention
We will retain and use your personal data for as long as necessary to fulfill our legal obligations, enforce our agreements, resolve disputes, and where longer retention is not required or permitted by law. We may continue to use any information derived from your personal data after you update or delete it, but in a way that does not personally identify you. Once the retention period expires, your personal data will be deleted. Therefore, your right to access, delete, correct, or transfer data cannot be exercised after the retention period has ended.
10. Data Transfers
Depending on your location, data transfers may involve transmitting and storing your information in a different country, including the UAE. Transfers of your personal data to countries outside the European Union will only occur with your explicit consent or under the conditions outlined in the GDPR, and always with your best interests in mind. You have the right to be informed about the legal grounds for transferring your data to a non-EU country or any international organization governed by public international law or created by two or more countries, such as the United Nations, as well as the security measures we have in place to protect your information. If such a transfer occurs, you can learn more by reviewing the relevant sections of this Policy or contacting us using the details provided in the "Contact Us" section.
11. Data Protection Rights under GDPR
If you are a resident of the European Economic Area (EEA), you have certain data protection rights, and we are committed to taking reasonable steps to allow you to access, correct, delete, or limit the use of your personal data. If you wish to know what personal data we hold about you and if you want it removed from our systems, please contact us. In certain circumstances, you have the following rights:
11.1. If your consent is the legal basis for processing your personal data, you can withdraw it at any time. This will not affect the lawfulness of processing based on your consent before its withdrawal.
11.2. You have the right to know if we are processing your personal data, to receive information about certain aspects of the processing, and to obtain a copy of your personal data that is being processed.
11.3. You have the right to verify the accuracy of your data and request that it be updated or corrected. You also have the right to request that we supplement any incomplete personal data.
11.4. You have the right to object to the processing of your personal data. If you object, we will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms. However, if your personal data is processed for direct marketing purposes, you may object to such processing at any time without providing any justification. To find out whether we process personal data for direct marketing purposes, please refer to the relevant sections of this Policy.
11.5. You have the right, in certain circumstances, to restrict the processing of your personal data. These circumstances include: if you contest the accuracy of your personal data and we need to verify it; if the processing is unlawful, but you oppose the deletion of your personal data and request its restricted use instead; if we no longer need your personal data for processing purposes, but you require it for the establishment, exercise, or defense of legal claims; or if you have objected to the processing, pending the verification of whether our legitimate grounds override your own. If processing is restricted, your personal data will only be processed, except for storage, with your consent or for the establishment, exercise, or defense of legal claims, or to protect the rights of another person, or for reasons of important public interest.
11.6. You have the right, in certain circumstances, to request the deletion of your personal data. These circumstances include: when the personal data is no longer necessary for the purposes for which it was collected or otherwise processed; when you withdraw your consent to processing based on consent; when you object to processing under certain applicable data protection laws; when the personal data was unlawfully processed; or when the personal data is processed for direct marketing purposes. However, there are exceptions to the right to deletion, such as when processing is necessary for exercising the right to freedom of expression and information, for compliance with legal obligations, or for the establishment, exercise, or defense of legal claims.
11.7. You have the right to receive your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format, and, where technically feasible, to have it transferred to another data controller without hindrance from us, provided that such transfer does not adversely affect the rights and freedoms of others.
11.8. You have the right to lodge a complaint with the data protection authority in your country regarding our collection and use of your personal data. If you believe that the processing of your personal data violates applicable data protection laws, you have the right to file a complaint with the relevant supervisory authority. The supervisory authority depends on the country in which you reside. This provision applies as long as the personal data is processed by automated means and the processing is based on the User's consent, a contract to which the User is a party, or pre-contractual obligations.
12. Exercising Your Rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must include sufficient information for us to confirm that you are the person you claim to be or that you are authorized to act on behalf of such a person. If we receive your request from an authorized representative, we may request proof that you have authorized the representative or that the representative has valid written authority to submit requests on your behalf.
You must provide enough information to help us understand the request and respond appropriately. We cannot respond to your request or provide you with personal information unless we first verify your identity or authority to make such a request and confirm that the personal information relates to you.
13. Use of Cookies
Our Website and Services use cookies to help personalize your online experience. Cookies are small text files sent by a web server to your browser to track activity on a specific website. These files are stored locally on your device’s hard drive. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are unique to the User's profile and can only be read by the web server in the domain that issued the cookie. We may use cookies to collect, store, and track information for security, personalization, and statistical purposes. Please note that you can choose to accept or decline cookies. Most web browsers automatically accept cookies by default, but you can modify your browser settings to block or delete cookies.
14. Data Analytics
Our Website and Services may use third-party analytics tools that use cookies, web beacons, or other similar technologies to collect information as part of our analytics efforts to help us understand how Users engage with our Website and Services. The information collected is used to compile statistical reports on User activity, including how often and how long Users visit our Website and Services. We use the information gathered from these analytics tools to monitor and improve the performance of our Website and Services. We do not use third-party analytics tools to track or collect any personal information about our Users, and we do not link any statistical information to specific Users.
15. Do Not Track Signals
All major web browsers offer a "Do Not Track" feature that allows websites to notify that you do not want to be tracked. Tracking refers to the collection of personal information from consumers who use or visit a website or online service as they move across different websites over time. However, there is no standard for interpreting or responding to Do Not Track signals. As a result, our Website and Services are not currently configured to respond to Do Not Track signals transmitted by your browser. Nevertheless, as detailed in this Policy, we limit the use and collection of your personal data.
16. Advertising
We may display online advertisements and share non-identifying information about our customers that we or our advertisers collect during your use of the Website and Services. We do not share personal information that would allow advertisers to identify specific individuals. In some cases, we may use this collected non-identifying information to provide targeted advertising to specific audiences. We may also allow third-party companies to help us tailor ads that we believe might interest Users by collecting and using additional data about User activities on the Website. These companies may deliver ads that place cookies and track User behavior on the Website.
17. Social Media Features
Our Website and Services may include social media features such as Facebook and Twitter buttons, "Share" buttons, and others (collectively referred to as "Social Media Features"). These features may collect information such as your IP address and which page you are visiting on our Website, and may place cookies to allow the features to function properly. Social Media Features are either hosted by their respective providers or directly on our Website. Your interactions with these features are governed by the privacy policy of the respective provider.
18. Email Marketing
We offer email newsletters that you may subscribe to voluntarily at any time. We are committed to keeping your email address confidential and will not disclose your email address to third parties except as allowed under the "Use and Processing of Information" section or as required by third-party service providers to send such emails. We will store any email communication in compliance with applicable laws and regulations. In accordance with anti-spam laws, all emails sent from us will clearly state the sender and include information on how to contact them. You can opt out of receiving our newsletters or marketing emails by following the unsubscribe instructions included in those emails or by contacting us directly. However, you will continue to receive essential transactional emails.
19. Push Notifications
We offer push notifications, which you can voluntarily subscribe to at any time. To ensure push notifications reach the correct devices, we use a third-party push notification provider, which relies on a unique device token assigned by your device’s operating system. Although device tokens are accessible, they do not reveal your identity, your device's unique identifier, or your contact information to us or our third-party push notification provider. We store information sent through email in compliance with applicable laws and regulations. If you wish to stop receiving push notifications at any time, simply adjust your device settings accordingly.
20. Affiliate Links
We may engage in affiliate marketing and include affiliate links on the Website and within the Services to offer you relevant or supplementary products and services. When you click on an affiliate link, a cookie will be placed in your browser to track any sales for the purpose of earning a commission.
21. Links to Third-Party Websites
The Website and Services may contain links to third-party websites that are not owned or controlled by us. Please note that we are not responsible for the privacy practices of such other websites or third parties. We recommend that you be aware of when you leave the Website and Services and review the privacy policy of each website that may collect personal data.
22. Data Security
We store the information you provide on computer servers in a controlled and secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and disclosure of personal data under our control. However, no data transmission over the Internet or wireless network can be guaranteed. As a result, while we strive to protect your personal data, you acknowledge that (1) there are security and privacy limitations of the Internet that are beyond our control; (2) the security, integrity, and privacy of any information and data exchanged between you and the Website and Services cannot be guaranteed; and (3) any such information and data may be viewed or altered by a third party during transmission, despite our efforts. The security of personal data also depends in part on the security of the device you use to communicate with us and the security measures you use to protect your login credentials. Please take appropriate measures to protect this information.
23. Data Breach
If we become aware that the security of the Website and Services has been compromised or Users' personal data has been disclosed to unrelated third parties due to external activity, including, but not limited to, security attacks or fraud, we reserve the right to take appropriate measures, including, but not limited to, investigation and reporting, as well as notifying law enforcement authorities and cooperating with them. In the event of a data breach, we will take all necessary measures to notify affected individuals if we believe there is a reasonable risk of harm to the User as a result of the breach or if notification is otherwise required by law. When we do so, we will post a notice on our Website and send you an email.
24. Changes and Amendments
We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also notify you in other ways at our discretion, such as through the contact information you have provided. The updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or any other act specified at that time) will constitute your acceptance of those changes. However, without your consent, we will not use your personal data in a manner that is materially different from what was stated at the time your personal data was collected.
25. Acceptance of this Policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information, you agree to be bound by this Policy. If you do not agree to comply with the terms of this Policy, you are not authorized to access or use the Website and Services.
26. Contacting Us
If you have any questions about the information we hold about you or wish to exercise your rights, you can use the following form to submit your request: Submit a Data Access Request. If you have any other questions, concerns, or complaints regarding this Policy, we encourage you to contact us using the information below: office@gwc.ae We will endeavor to resolve any complaints and disputes and take all necessary measures to ensure you can exercise your rights as quickly as possible and in any case within the timeframes provided by applicable data protection laws.
Last updated on May 6, 2023.
Tilda Publishing
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