Personal Data Policy

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Date of publication: 01.01.2024 
Date of entrance into force: 01.01.2024 
 
Responsibility 
 
This Privacy Notice is provided by CYBERIA PROJECT MANAGEMENT SERVICES — SOLE PROPRIETORSHIP L.L.C. (License No: CN-4790910, Office 114, Cloud Spaces, Yas Island, Yas Mall, Abu Dhabi, U.A.E) and CYBERIA INTERNATIONAL L.L.C-FZ (License No: 2202593.01, Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E) hereinafter «Cyberia», «we», «us», «our», for and on behalf of itself and the various entities operating as part of the Cyberia across the world.  
 
Our organization places a high priority on protecting and respecting the privacy of your personal data. This Privacy Policy outlines our dedication to responsibly handling any personal data we collect in conducting our business activities, including the data we receive directly from you. In this document, we detail the methods and purposes for which we collect, store, and utilize personal data. Additionally, it provides an overview of the rights available to individuals whose personal data is processed by us. 
 
Under relevant data protection legislation, Cyberia generally serves as the ’data controller’ for any personal information you provide to us. This means your personal data will be managed by the specific Cyberia entity you engage with, or that delivers services or communication to you. In rare instances, based on specific agreements, we operate as a ’processor.’ In this role, we handle personal data strictly as directed by a data controller or in a manner allowed by law. 
We encourage you to thoroughly review this section to gain insight into our policies and procedures surrounding the management of personal information. Should you have any questions about our data protection practices that are not addressed in this Privacy Notice, feel free to reach out to us using the contact information provided at the conclusion of this document.  
 
Gathering of Personal Information 
 
In our regular business operations, we might gather your personal information during various interactions. This includes occasions when you contact us, request information, seek our services, use our website, or through your connections with our staff or clients. 
We typically process the following types of personal information: 
1. Basic Information: Your name, job title/role, employer details, relationship status, and contact details such as email, physical address, and phone numbers. 
2. Identity Verification: Details for confirming your identity, like your birth date and passport details, including information from public sources for verification. 
3. Service-related Information: Data pertaining to the services you require from us. 
4. Financial Details: Bank account or other financial information relevant to our engagement. 
5. Technical Data: Includes information from your website or app visits (e.g., interaction, duration) and your digital footprint (like IP address, browser specifics, and geolocation). 
6. Visit Records: Details of your visits to our offices or events, such as appointment specifics, CCTV footage, and other imaging data. 
7. Client-provided Information: Personal data provided by or on behalf of our clients, including special categories of data, generated in the course of service provision. 
8. Miscellaneous Information: Any other personal details you may offer. 
Sources of Information Collection 
• During client onboarding, service requests, or client maintenance. 
• When you apply for employment or engage with our alumni network. 
• When you or your employer offer services to us. 
• In case of matters involving you or your employer. 
• Through interactions with our website. 
• Engagements with our marketing or event initiatives. 
We primarily gather this information directly from you or via your interaction with our website. Sometimes, it may be collected from third parties such as clients, your employer, other involved parties, tech platform operators, associated organizations, authorities, credit agencies, or public records. 
 
Confidentiality and Protection 
 
Your provided information is regarded as confidential. We uphold this confidentiality and protect your data in line with our professional responsibilities and applicable laws. We have measures in place with our personnel and service providers who handle your personal data, ensuring confidentiality is preserved. 
 
Usage Objectives 
 
We handle your personal data, whether received directly from you or a third party, under specific conditions. These include having your consent, or operating on a lawful basis such as fulfilling a contract with you, complying with legal obligations, protecting vital interests, or pursuing our legitimate interests or those of a third party, provided these do not infringe upon your rights. 
Our processing of your personal information serves various purposes: 
1. Service Provision: To deliver services you request. 
2. Communication: To update you on developments and promote our services. 
3. Business Relationship Management: Managing our interaction with you or your organization, including service provision, procurement of your goods or services, or in an employment context. This encompasses payment processes, accounting, auditing, billing, collections, and support services. 
4. Legal Compliance: Adhering to legal and regulatory requirements, such as anti-money laundering and sanctions checks, audits, and regulatory inquiries. 
5. Security Management: Securing and managing access to our premises and IT systems, and overseeing our technology operations. 
6. Data Accuracy: Ensuring your contact information is up-to-date using data you provide or publicly available information. 
7. Ancillary Purposes: For any related or auxiliary reasons to the above, or for other purposes where your personal data was initially provided to us.  
 
Cookies 
 
Cookies are tiny data files sent to your computer’s hard drive by a web server. They play a crucial role in recognizing users on our website. These cookies can gather data about your usage of our websites and general information about your computer, like your IP address and browser type. They also help in collecting demographic information. We utilize cookies to enhance the functionality and user experience of our website. 
In particular, our cookies are used for tracking the number of unique visitors to our site and app, recording details such as a unique visitor ID, the time and date of the first visit, the start of the current visit, and the total number of visits made. They also help in monitoring session information to attribute website interactions, including conversions and transactions, to a particular source of web traffic. Moreover, they indicate the end of a website visit and the closure of the browser. Most web browsers offer options to alert you when you receive a new cookie, and provide methods to reject new cookies or disable them entirely, should you choose to do so. 
 
Distribution of Your Personal Data 
 
We may share your personal information under certain circumstances, such as: 
1. Outsourcing Functions: For delegating one or more of the tasks related to the purposes mentioned earlier. 
2. Verification and Updates: To verify or update the information you have provided. 
3. Communication: To inform you about events, updates on our services, and other key information. 
4. Other Notified Purposes: For reasons specified at or before the time of data collection. 
Should there be a reorganization of our business, it may become necessary to transfer your personal data to other entities within our group or to external third parties. 
Additionally, we may disclose your data to third parties as required to deliver our services effectively. This includes, but is not limited to, sharing with our professional advisors such as lawyers and accountants, governmental or regulatory authorities, professional indemnity insurers, tax authorities, document processing and transaction services, corporate registries, counsel, arbitrators, mediators, clerks, witnesses, experts, and third-party postal and courier services. Such disclosures are made either with your consent, as mandated by law, or when necessary for legal proceedings, or to establish, exercise, or defend legal rights. We assure you that your personal information is not sold, rented, distributed, or made commercially available to any third party without proper justification. 
 
Cross-Border Transfer of your Information 
 
Occasionally, it becomes essential for us to distribute your personal information across different locations within Cyberia or with our global partners in professional services. This includes transferring your data to data storage facilities or online storage, which might be located both within and outside the United Arab Emirates, operated by us or by independent service providers. 
We recognize that the standards of personal information protection can vary across different jurisdictions. Some may not offer a level of protection considered adequate from an international viewpoint. To mitigate this, we have implemented procedures and safeguards designed to protect your personal information. These measures include contractual commitments ensuring that all relevant parties maintain the confidentiality and security of your personal information and use it solely for the designated purposes we have outlined to you. 
When your information is transferred internationally, we are committed to handling, sharing, and protecting it in accordance with the principles set out in this Privacy Notice. 
Duration of Personal Information Retention 
We hold onto your personal information only as long as necessary to accomplish the objectives for which it was originally collected. This duration may extend if we mutually agree upon a longer retention period, or if a longer period is mandated or allowed under applicable law. 
 
Your Rights 
 
Depending on the situation and relevant laws, you may have various rights regarding your personal data. Here’s a summary of the key rights that are commonly applicable: 
1. Withdrawal of Consent: If your personal information is processed based on your consent, you have the right to withdraw that consent at any time. Please note that this withdrawal doesn’t affect the lawfulness of any processing done before you withdrew your consent. 
2. Access, Rectification, and Erasure: You can request access to your personal information and ask for it to be corrected or deleted. You also have the right to request a limitation on its processing, to object to processing, and to data portability. 
3. Objections and Restrictions: You have the right to object to the processing of your personal information on legitimate grounds or to request a restriction on processing. 
4. Filing Complaints: If you believe your data protection rights have been violated, you have the right to file a complaint with the appropriate data protection authority. 
Should you wish to exercise any of these rights, or any other rights you have under applicable law, please reach out to us using the contact details provided below. 
 
 
Information Security 
We have implemented reasonable administrative, technical and physical measures to protect your personal information against loss, misuse and alteration.  
 
Changes to this Privacy Notice 
 
We may from time to time make changes to this Privacy Notice. These will become effective once the amended Privacy Notice is posted on our website. Please check back regularly to keep informed of updates to this Privacy Notice. 
 
Contact Details 
 
CYBERIA PROJECT MANAGEMENT SERVICES — SOLE PROPRIETORSHIP L.L.C.,  
License No: CN-4790910,  
Office 114, Cloud Spaces, Yas Island, Yas Mall, Abu Dhabi, U.A.E 
Phone: +971 2 410 35 00 
 
CYBERIA INTERNATIONAL L.L.C-FZ 
License No: 2202593.01 
Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E 
Phone: +971 2 410 36 17 
 
Email: info@cyberia-tech.com