WEBSITE PRIVACY POLICY 

Introduction

Welcome to the privacy policy of KLAIM Holdings Limited (referred to as the “Company”, "we," "us," or "our" throughout this Privacy Policy). We value your privacy and are committed to protecting your personal data. This Privacy Policy will provide you about details on how we handle your personal data when you access our website (regardless of the location from which you access our website) and inform you about your privacy rights and the legal protections in place to ensure your privacy.

Please refer the Glossary to understand some of the terms used in this Privacy Policy.

1. Important Information and our Identity 

Purpose of this Privacy Policy 

This Privacy Policy aims to give you information on how the Company collects and processes your personal data when you use this website, including any data you may provide through this website.

Please note that 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 any other privacy policy or fair processing policy that we may provide on specific occasions when we collect or process your personal data or information. This is to ensure that we fully provide you with the necessary information for you to have a complete understanding of how and why we are collecting or processing your data. This Privacy Policy complements other notices and privacy policies and is not intended to override them.

Controller

The Company is the controller and is responsible for your personal data.

If you have any inquiries regarding this Privacy Policy, including any requests to exercise your legal rights, please be free to contact us using the contact information set out below.

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

We keep our privacy policy under regular review. This version was last reviewed and updated on 6 July 2023.

It is important that the personal data we hold about you is accurate and up-to-date. Therefore, please inform us promptly if your personal data changes during your relationship with us.

Third-Party links 

On this website, you may encounter links to third-party websites, plug-ins, and applications. Clicking on those links or enabling such 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 recommend that you carefully read the privacy policy of every website you visit.

2. The data we collect about you 

Personal data, or personal information, refers to any information that can directly or indirectly identify an individual. It excludes data where the identity has been removed such as anonymous data.

We may collect, use, store, and transfer various types of personal data about you which we have categorized as follows:

1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender;
2. Contact Data includes billing address, delivery address, email address, and telephone numbers;
3. Financial Data includes bank account and payment card details;
4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;
5. 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;
6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses;
7. Usage Data includes information about how you use our website, products, and services; and
8. 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 anonymized statistical or demographic information. Aggregated Data could be derived from your personal data but is not considered personal data under the law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to determine the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data in a manner that can directly or indirectly identify you, we treat the combined data as personal data and handle it in accordance with this Privacy Policy.

If you fail to provide Personal Data 

In situations where we are required by law, or have a contractual obligation to collect personal data from you, and you fail to provide the requested data, we may be unable to fulfill the contract we have or are trying to enter into with you. For example, if we need necessary information to provide you with goods or services, we may have to cancel a product or service you have with us. However, if such a situation arises, we will notify you accordingly.

3. How is your personal data collected? 

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

1. Direct interactions. You may provide us with your personal data by filling out forms or corresponding with us via post, phone, email, or other means of communication.
2. Automated technologies or interactions. When you interact with our website, we automatically collect Technical Data about your equipment, browsing activities actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
3. Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below.
4. Technical Data from the following parties:
   1. Analytics providers;
   2. Advertising networks; and
   3. Search information providers.
5. Contact, Financial and Transaction Data from providers of technical, payment, and delivery services.
6. Identity and Contact Data from data brokers or aggregators.
7. Identity and Contact Data from publicly available sources.

4. How we use your Personal Data

We will only use your personal data when permitted by law. The most common circumstances under which we use your personal data are as follows:

1. Contractual Necessity: We use your personnel data when it is necessary to fulfill the contract we are about to enter into or have entered into with you;
2. Legitimate Interests: We may use your personnel data when it is necessary for our Legitimate Interests or the legitimate interests of a third party, provided that your interests and fundamental rights do not override those interests; or
3. Legal Obligation: We may use your personnel data to comply with a legal obligation.

In general, we do not rely on your consent as a legal basis for processing your personal data. However, we will seek your consent before sending you direct marketing communications from third parties via email or text message. You have the right to withdraw consent for marketing purposes at any time by contacting us.

Purposes for which we will use your Personal Data 

In the table, we have provided a description of how we intend to use your personal data along with the legal bases on which we rely for each purpose. We have also indicated our Legitimate Interests where applicable.

Please note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. If you require further details regarding the specific legal ground we rely on for processing your personal data when multiple grounds are mentioned in the table below, please reach out to us.

Marketing 

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

Promotional offers from us 

In order to provide you with relevant products, services, and offers, We may analyse your Identity, Contact, Technical, Usage and Profile Data to understand your preferences and interests. This is how we determine which products, services and offers are likely to be of interest to you ( referred to as marketing).You will receive marketing communications from us if you have requested information from us or purchased from us and you have not opted out of receiving that marketing.

Third-party marketing 

We will obtain your explicit opt-in consent before sharing your personal data with any third party for marketing purposes.

Opting out 

You may have the option that we or third parties cease sending you marketing messages at any time by contacting us or the third party directly.

Cookies 

A cookie is a small text file which is placed on your device when you access our website. We use cookies and other online tracking devices to make your online experience more efficient and enjoyable. You may set your browser settings to reject all or some browser cookies, or to receive alerts when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose 

We will only use your personal data for the purposes for which it was initially collected, unless we reasonably consider that we need to use it for another purpose that is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where it is required or permitted by law.

5. Disclosures of your Personal Data 

We may share your personal data with the following parties for the purposes outlined in the table set out in the “Purposes for which we will use your Personal Data” section:

1. Internal Third Parties;
2. External Third Parties;
3. third parties involved in the sale, transfer or merger of parts of our business or assets. If a change of control occurs in our business, the new owners may use your personal data in the same manner as described in this Privacy Policy;
4. any other third party if we have a legal obligation to disclose or share your personal data, or to protect the rights, property and safety of the Company, our personnel or others; and
5. any other third party when required by a court, regulator or government agency, such as complying with a search warrant or court order or applicable law or regulation.

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 all in accordance with our instructions.

6. Cross-Border Transfers

We do not transfer your personal data outside the UAE

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

Please feel free to contact us if you would like further information about the specific mechanism we use when transferring your personal data out of the UAE.

7. Data Security 

We have implemented appropriate security 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 bound by confidentiality obligations.

However, it is important to note that no transmission of data over the internet is guaranteed to be completely secure. It may be possible for unauthorized third parties to intercept or access transmissions or private communications unlawfully. While we strive to protect your personal data, we cannot ensure or warrant the security of any personal data you transmit to us. Any such transmission is done at your own risk. If you believe that the security of your interaction with us has been compromised, please contact us.

We have established procedures to deal with any suspected personal data breaches, and where legally required, we will notify you and the applicable regulatory authority of such breaches.

8. Data Retention 

How long will my personal data be used? 

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for an extended 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.

To determine the appropriate retention period for personal data, we consider the quantity, nature, and sensitivity of the personal data, the potential risk of harm associated with unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and any applicable legal, regulatory, tax, accounting, or other requirements.

In some circumstances, you can request the deletion of your data: see Your Legal Rights at section 9 below for further information.

In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this anonymized information indefinitely without further notice to you.

Whilst we continue to process your personal data we ensure that it is treated in accordance with this Privacy Policy. Otherwise, we securely erase your information once it is no longer needed.

9. Your Legal Rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. The various rights are not absolute and each is subject to certain exceptions or qualifications. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under data protection laws. Nothing in this privacy policy is intended to provide you with rights beyond or in addition to your rights as a data subject under data protection laws. You have the right to:

1. 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;
2. 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;
3. request erasure of your personal data. This enables you to request the deletion or removal of your 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. Please note 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;
4. 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 that leads you to object to the processing as it impacts your fundamental rights and freedoms. You also have the right to object when we process your personal data for direct marketing purposes. In some cases, we may demonstrate compelling legitimate grounds to process your information which override your rights and freedoms;
5. 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:
   1. where you want us to establish the data's accuracy;
   2. where our use of the data is unlawful but you do not want us to erase it;
   3. 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; or
   4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
6. request the transfer of your personal data to yourself 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; and
7. withdraw consent at any time when 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.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not ordinarily have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to expedite our response.

Time limit to respond

We make every effort to respond to all legitimate requests within one month. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Legitimate Interest means the interest of our business in conducting and managing our operations to enable us to provide you with the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our Legitimate Interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). If you would like further information on how we assess our Legitimate Interests against any potential impact on you in respect of specific activities, please contact us.

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.