Privacy Notice
Introduction
We are committed to protect and respect your right to privacy. This Privacy Notice (“Notice”) governs the collection and use of personal data by Harlyz FZ LLE (“the Company”). This Notice describes how and why we use any personal data you provide to us, as well as information we might obtain from other sources.
Your personal data may be used for any of the purposes specified in this Notice, or for additional purposes that we notify you of when your personal data is being collected. For more information about the Company, please see www.harlyz.com
In this Notice, references to “our,” “us,” or “we” refer to the Company.
Any references to “you” or “your” refers to the relevant individual who is the subject of the personal data.
Who are we?
The Company is the data controller for the purposes of any applicable data protection laws.
Definitions covered in this Notice
When we refer to “processing” your “personal data” in this Notice, we qualify this as any action done with or in connection with your personal data (this includes gathering, storing, and deleting such personal data). Any information that can be used to locate or (in)directly identify you is considered as “personal data”.
Examples of personal data are birth date, age, gender, nationality, passport, marital status, signature, country of residence, place of birth, photo, family details, voice recordings, religion, spoken languages, emergency contact information, insurance information, driver’s license number.
What types of personal data do we collect from you?
We process different categories of personal data further described below.
Contact Details: Contact details is personal data that helps us to contact you, such as your address, email address and phone number.
Identification Data: Identification Data is personal data that helps us identify you, such as your name, title, copy of your passport, Emirates ID, driver’s license, proof of utility bills etc.
Sensitive personal data: This category of personal data is considered as sensitive by law. Examples of sensitive personal data are your health data or your biometric data or a copy of your photo.
Account data: Account data is security-related data (including usernames and passwords, authentication methods, and roles), service-related data (including purchase history and account profiles), billing-related data (including payment, shipping, and billing information) etc.
User-generated content: User-generated content is personal data when you participate in a community forum or otherwise post content that others can read or view, such as your comments, username, or profile picture.
Geolocation Data: Geolocation data is personal data such as the location of your device.
Web Data: Web data is personal data collected via our websites such as cookies, user activity records, IP addresses, social media profiles, device identifiers, and information about your interactions on our websites.
Financial Data: Financial data is personal data related to your finances such as your bank and card information.
For what purposes do we process your personal data?
Description of Processing
Category of Personal Data
Legal Basis
We process your personal data during the registration process when you subscribe to our newsletter, attend our conferences or events, and/or receive our emails.
Contact Details, Identification Data, Account data, User-generated content, Geolocation Data, Web Data, and Financial Data
Consent, Performance of Contract
We process your personal data when you register for an event or conference organized by the Company.
Contact Details, Identification Data, Account data, User-generated content, Geolocation Data, Web Data, and Financial Data
Consent
We process your personal data in the form of user content when you communicate with us, send us messages, ask questions, offer feedback, submit queries, or post anything on the Company website.
Contact Details, Identification Data, Account data, User-generated content, Geolocation Data, Web Data, and Financial Data
Consent
We process your personal data so we can monitor the quality of our services to you, to conduct surveys, obtain feedback and manage and progress complaints as necessary.
Contact Details, Identification Data, Account data, User-generated content, Geolocation Data, Web Data, and Financial Data
Consent
We process your personal data for marketing and analytical purposes, including managing our loyalty programs and customizing offers for you.
Contact Details, Identification Data, Account data, User-generated content, Geolocation Data, Web Data, and Financial Data
Consent, Performance of Contract
We process your personal data to fulfil our legal obligations and to investigate or defend legal claims.
Contact Details, Identification Data, Sensitive data, Account data, User-generated content, Geolocation Data, Web Data, and Financial Data
Legal obligation
We process your personal data to protect and secure our IT systems or for backup and archiving purposes or to prevent a potential data breach.
Contact Details, Identification Data, Account data, User-generated content, Geolocation Data, Web Data, and Financial Data
Performance of Contract
We process your personal data to safeguard the safety and security of all customers and employees in our buildings or properties either owned or rented.
Identification Data and Sensitive Personal Data
Protection of the interest of the data subject
Retention of Personal Data
We only retain your personal data for as long as necessary to carry out the purposes indicated in this Notice. After this period, we will securely delete your personal data, unless we are obligated to retain your personal data to comply with a legal or regulatory requirement or to deal with any potential disputes.
If we no longer need to keep your personal data, we will delete it from our systems and records and/or take steps to properly anonymize it so that you cannot be identified from it.
Your rights
You have certain rights that you can exercise. Please send an email to info@harlyz.com to exercise your rights. The following rights may be applicable to you, depending on the jurisdiction where your personal data is processed:
Data Privacy Right
What does it mean?
Right to access your data
You have the right to request from us a summary or a copy of the personal data we have on file about you.
Right to have your data updated or deleted
You have the right to request that we immediately amend any inaccurate or missing personal data we may have about you along with the right to request that your personal data be deleted if it is no longer needed or processing it is prohibited by law.
Right to limit or stop data processing
You have the right to limit how your personal data is processed in certain situations.
Right to request transfer of personal data or data portability
You have the right to obtain your personal data in an organized, machine-readable manner, or request to transfer it to a third party.
Right to raise objections to data processing
You have the right to raise an objection to the processing of your personal data.
Right to revoke consent
You have the right to revoke your consent at any point The legitimacy of processing done using your consent prior to its revocation will remain unaffected by the withdrawal of your consent.
Right to file a complaint
You have a right to file a complaint with the
Emirates Data Office or the relevant supervisory authority in your country if you believe that we have not complied with the applicable data protection laws.
It is important to note that the rights stated above are not absolute and that not every request can be fully granted. In certain cases, for instance where we are required to retain your personal data by contracts or the law, we might not be able to delete it or limit its processing.
With whom do we share your personal data?
We may share your personal data with:
Our service providers, business partners, and affiliates
Authorized third-parties
Other third parties required by law.
We regulate how and with whom we share your personal data. We may disclose your information for purposes such as payment processing, order fulfilment, product installation, customer service, marketing, financing, servicing or repair, and other similar operations.
Category of Recipient
Purpose for Sharing
Affiliates and subsidiaries
To facilitate, operate, improve, or fulfil our services
Service providers and business partners
To facilitate, operate, improve, and fulfil our services to you on our behalf we may want to outsource certain functions.
Financial institutions
To verify your eligibility and process your service request based on your consent or our contract with you.
Law enforcement and government authorities
To ensure compliance with the relevant laws based on our legal obligations
It is important to note that the rights stated above are not absolute and that not every request can be fully granted. In certain cases, for instance where we are required to retain your personal data by contracts or the law, we might not be able to delete it or limit its processing.
How do we secure your personal data
We have adopted appropriate technological and operational security measures to protect your personal data against loss, abuse, alteration, or destruction. Only authorized people have access to personal data, and these individuals are contractually bound to keep it confidential. We require our suppliers and vendors to implement appropriate safeguards when they access or use personal data that we share with them.
Automated Decision Making/Profiling
Our artificial intelligence technologies may enable automated data processing in several fields. This is called “profiling”. If we make use of profiling, we will always obtain your consent. We will also conduct privacy impact assessments to implement appropriate measures to protect your rights.
When we make use of profiling, you have the right to object against it. This right can be invoked by using the contact details provided in the “Contact Us” section below.
Privacy Centre
Our Privacy Centre enables you to customize your consent preferences. By clicking on settings centre located on the website you can manage your consent given to us.
Contact Us
If you have any questions or concerns about this Notice, please contact us at info@harlyz.com.
Updates to the Notice
This Notice may be updated on a regular basis to reflect new developments. We reserve the right to update, add, or remove portions of this Notice at any time. You are also advised to revisit this Notice periodically for updates.
The most recent update to this Notice will be indicated below.