SAFIR PRIVACY POLICY 

Last updated: 10-06-21

1. General Scope 

This Privacy Policy describes SAFIR’S policies and procedures on the collection, use and disclosure of the Customer’s information when the Customer use SAFIR’S Services (hereinafter the “Service/s”) and tells the Customer about the Customer’s privacy rights and how the law protects the Customer.

SAFIR uses the Customer’s Personal data to provide and improve the Service. By using the Service, the Customer agrees to the collection and use of information in accordance with this Privacy Policy. Please also read the Terms and Conditions to use SAFIR’S Services.

2. Interpretation and Definitions 

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

  • Account means a unique account created for the Customer to access SAFIR’S Services or parts of SAFIR’S Services.
  • Company (referred to as either „the Company“, „We“, „Us“ or „Safir’s“ in this Agreement) refers to SAFIR Global DMCC with registered address in Fortune Tower, Office 2703, Jumeirah Lake Towers, Cluster C Street, Dubai, United Arab Emirates.
  • For the purpose of the GDPR, the Company is the Data Controller.
  • Cookies are small files that are placed on the Customer’s computer, mobile device or any other device by a website, containing the details of the Customer’s browsing history on that website among its many uses.
  • Country refers to: United Arab Emirates
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • For the purposes of GDPR, Personal Data means any information relating to the Customer such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
  • Service refers to Safir’s Website, it’s portal and associated Services as defined in Safir’s General Terms and Conditions.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers also to any third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how
  • the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to SAFIR’S website and portal, accessible at www.safir.com
  • The Customer means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), the Customer can be referred to as the Data Subject or as the User as the Customer are the individual using the Service.

3. Collecting and Using the Customer’s Personal Data 

Types of Data Collected

Personal Data 

While using Safir’s Service, We may ask the Customer to provide Us with certain personally identifiable information that can be used to contact or identify the Customer. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Bank account information in order to pay for products and/or services within the Service
  • Usage Data

When the Customer pay for a product and/or a service via bank transfer, We may ask the Customer to provide information to facilitate this transaction and to verify the Customer’s identity. Such information may include, without limitation:

  • Date of birth
  • Passport or National ID card
  • Bank card statement
  • Other information linking the Customer to an address

Usage Data 

Usage Data is collected automatically when using the Service.

Usage Data may include information such as the Customer’s Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Safir’s Service that the Customer visits, the time and date of the Customer’s visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When the Customer access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device the Customer use, the Customer’s mobile device unique ID, the IP address of the Customer’s mobile device, the Customer’s mobile operating system,

the type of mobile Internet browser the Customer use, unique device identifiers and other diagnostic data.

We may also collect information that the Customer’s browser sends whenever the Customer visit Safir’s Service or when the Customer access the Service by or through a mobile device.

Tracking Technologies and Cookies 

We use Cookies and similar tracking technologies to track the activity on Safir’s Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Safir’s Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on the Customer’s Device. The Customer can instruct the Customer’s browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if the Customer do not accept Cookies, the Customer may not be able to use some parts of Safir’s Service. Unless the Customer have adjusted the Customer’s browser setting so that it will refuse Cookies, Safir’s Service may use Cookies.

Cookies can be „Persistent“ or „Session“ Cookies. Persistent Cookies remain on the Customer’s personal computer or mobile device when the Customer go offline, while Session Cookies are deleted as soon as the Customer close the Customer’s web browser.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide the Customer with services available through the Website and to enable the Customer to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that the Customer have asked for cannot be provided, and We only use these Cookies to provide the Customer with those services.

  • Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

  • Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices the Customer makes when the Customer uses the Website, such as remembering the Customer’s login details or language preference. The purpose of these Cookies is to provide the Customer with a more personal experience and to avoid the

Customer having to re-enter the Customer’s preferences every time the Customer use the Website.

  • Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify the Customer as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device the Customer uses to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how Safir’s users react to them.

  • Targeting and Advertising Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies track the Customer’s browsing habits to enable Us to show advertising which is more likely to be of interest to the Customer. These Cookies use information about the Customer’s browsing history to group the Customer with other users who have similar interests. Based on that information, and with Safir’s permission, third party advertisers can place Cookies to enable them to show adverts which We think will be relevant to the Customer’s interests while the Customer are on third party websites.

For more information about the cookies we use and the Customer’s choices regarding cookies, please visit Safir’s Cookies Policy or the Cookies section of Safir’s Privacy Policy.

4. Use of the Customer’s Personal Data 

The Company may use Personal Data for the following purposes:

  • To provide and maintain Safir’s Service, including to monitor the usage of Safir’s Service.
  • To manage the Customer’s Account: to manage the Customer’s registration as a user of the Service. The Personal Data the Customer provides can give the Customer access to different functionalities of the Service that are available to the Customer as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services the Customer have purchased or of any other contract with Us through the Service.
  • To contact the Customer: To contact the Customer by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the
  • functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide the Customer with news, special offers and general information about other goods, services and events which we offer that are similar to those that the Customer have already purchased or enquired about unless the Customer have opted not to receive such information.
  • To manage the Customer’s requests: To attend and manage the Customer’s requests to Us.
  • For business transfers: We may use the Customer’s information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about Safir’s Service users is among the assets transferred.
  • For other purposes: We may use the Customer’s information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Safir’s promotional campaigns and to evaluate and improve Safir’s Service, products, services, marketing and the Customer’s experience.

We may share the Customer’s personal information in the following situations:

  • With Service Providers: We may share the Customer’s personal information with Service Providers to monitor and analyze the use of Safir’s Service, to show advertisements to the Customer to help support and maintain Safir’s Service, for payment processing, to contact the Customer.
  • For business transfers: We may share or transfer the Customer’s personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Safir’s business to another company.
  • With Affiliates: We may share the Customer’s information with Safir’s affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Safir’s parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share the Customer’s information with Safir’s business partners to offer the Customer certain products, services or promotions.
  • With other users: when the Customer share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With the Customer’s consent: We may disclose the Customer’s personal information for any other purpose with the Customer’s consent.

5. Retention of the Customer’s Personal Data 

The Company will retain the Customer’s Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use the Customer’s Personal Data to the extent necessary to comply with Safir’s legal

obligations (for example, if we are required to retain the Customer’s data to comply with applicable laws), resolve disputes, and enforce Safir’s legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Safir’s Service, or We are legally obligated to retain this data for longer time periods.

6. Transfer of the Customer’s Personal Data 

The Customer’s information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of the Customer’s state, province, country or other governmental jurisdiction where the data protection laws may differ than those from the Customer’s jurisdiction.

The Customer’s consent to this Privacy Policy followed by the Customer’s submission of such information represents the Customer’s agreement to that transfer.

The Company will take all steps reasonably possible to ensure that the Customer’s data is treated securely and in accordance with this Privacy Policy and no transfer of the Customer’s Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of the Customer’s data and other personal information.

7. Disclosure of the Customer’s Personal Data 

Business Transactions 

If the Company is involved in a merger, acquisition or asset sale, the Customer’s Personal Data may be transferred. We will provide notice before the Customer’s Personal Data is transferred and before it becomes subject to a different Privacy Policy.

Law enforcement 

Under certain circumstances, the Company may be required to disclose the Customer’s Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a government agency).

Other legal requirements 

The Company may disclose the Customer’s Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

8. Security of the Customer’s Personal Data 

The security of the Customer’s Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect the Customer’s Personal Data, We cannot guarantee its absolute security.

9. Detailed Information on the Processing of the Customer’s Personal Data 

The Service Providers We use may have access to the Customer’s Personal Data. These third-party vendors collect, store, use, process and transfer information about the Customer’s activity on Safir’s Service in accordance with their Privacy Policies. We may use, but are not limited to the following Service Providers and services:

Analytics 

We may use third-party Service providers to monitor and analyze the use of Safir’s Service.

Google Analytics 

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Safir’s Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

The Customer can opt-out of having made the Customer’s activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Advertising 

We may use Service Providers to show advertisements to the Customer to help support and maintain Safir’s Service.

Google AdSense & DoubleClick Cookie 

Google, as a third party vendor, uses cookies to serve ads on Safir’s Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to Safir’s users based on their visit to Safir’s Service or other websites on the Internet.

The Customer may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Email Marketing 

We may use the Customer’s Personal Data to contact the Customer with newsletters, marketing or promotional materials and other information that may be of interest to the Customer. The Customer may opt-out of receiving any, or all,

of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to the Customer.

Mailchimp 

Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

Payments 

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect the Customer’s payment card details. That information is provided directly to Safir’s third-party payment processors whose use of the Customer’s personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

When the Customer use Safir’s Service to pay a product and/or service via bank transfer, We may ask the Customer to provide information to facilitate this transaction and to verify the Customer’s identity.

10. GDPR Privacy 

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: The Customer have given the Customer’s consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with the Customer and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect the Customer’s vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

The Customer’s Rights under the GDPR 

The Company undertakes to respect the confidentiality of the Customer’s Personal Data and to guarantee the Customer can exercise the Customer’s rights.

The Customer have the right under this Privacy Policy, and by law if the Customer are within the EU, to:

  • Request access to the Customer’s Personal Data. The right to access, update or delete the information We have on the Customer. Whenever made possible, the Customer can access, update or request deletion of the Customer’s Personal Data directly within the Customer’s account settings section. If the Customer is unable to perform these actions itself, the Customer shall contact Us to assist. This also enables the Customer to receive a copy of the Personal Data We hold about the Customer.
  • Request correction of the Personal Data that We hold about the Customer. The Customer have the right to have any incomplete or inaccurate information We hold about the Customer corrected.
  • Object to processing of the Customer’s Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Safir’s processing and there is something about the Customer’s particular situation, which makes the Customer want to object to Safir’s processing of the Customer’s Personal Data on this ground. The Customer also have the right to object where We are processing the Customer’s Personal Data for direct marketing purposes.
  • Request erasure of the Customer’s Personal Data. The Customer have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of the Customer’s Personal Data. We will provide to the Customer, or to a third-party the Customer have chosen, the Customer’s Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which the Customer initially provided consent for Us to use or where We used the information to perform a contract with the Customer.
  • Withdraw the Customer’s consent. The Customer have the right to withdraw the Customer’s consent on using the Customer’s Personal Data. If the Customer withdraw the Customer’s consent, We may not be able to provide the Customer with access to certain specific functionalities of the Service.

Exercising of the Customer’s GDPR Data Protection Rights 

The Customer may exercise the Customer’s rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask the Customer to verify the Customer’s identity before responding to such requests. If the Customer make a request, We will try Safir’s best to respond to the Customer as soon as possible.

The Customer have the right to complain to a Data Protection Authority about Safir’s collection and use of the Customer’s Personal Data. For more information,

if the Customer are in the European Economic Area (EEA), please contact the Customer’s local data protection authority in the EEA.

11. Children’s Privacy 

Safir’s Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If the Customer are a parent or guardian and the Customer are aware that the Customer’s child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Safir’s servers.

If We need to rely on consent as a legal basis for processing the Customer’s information and the Customer’s country requires consent from a parent, We may require the Customer’s parent’s consent before We collect and use that information.

12. Links to Other Websites 

Safir’s Service may contain links to other websites that are not operated by Us. If the Customer click on a third-party link, the Customer will be directed to that third party’s site. We strongly advise the Customer to review the Privacy Policy of every site the Customer visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

13. Changes to this Privacy Policy 

We may update Safir’s Privacy Policy from time to time. We will notify the Customer of any changes by posting the new Privacy Policy on this page.

We will let the Customer know via email and/or a prominent notice on Safir’s Service, prior to the change becoming effective and update the „Last updated“ date at the top of this Privacy Policy.

The Customer are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14. Contact Us 

All enquiries regarding this privacy policy may be directed by trackable letter sent by post to registered SAFIR office. To make sure that the sender of the letter is actually the respective Customer, this letter must be notarized.