PRIVACY POLICY 

Effective Date: 23 January 2025

1. GENERAL OVERVIEW
   • This Privacy Policy (“Policy”) provides you with information about how NOOR FOR CONSULTANCY AND DEVELOPMENT FZCO (“we”, “us” or “our”, including the subsidiaries and affiliates) collect, use, and share personal data at com or any application we may launch (the “Website”). This Policy will also apply to data gathered from you through other legitimate sources and when you apply for a job with us.
   • We develop long-term and successful relationships with our clients, partners, associates, and others cooperating with us. Data privacy is a key element of such relationships. We value and respect the personal data entrusted to us, aim to be transparent and responsible about how we handle the personal data, adhere to and respect privacy rights and all applicable laws, and do our best to approve our privacy and security practices constantly.
   • NOOR FOR CONSULTANCY AND DEVELOPMENT FZCO located at IFZA Business Park, DDP, Office 53683-001, Dubai, UAE is deemed a data controller with respect to the Personal Data.
   • We may amend this Policy anytime, with or without notifying you, by posting the restated version on the Website. Please ensure you have read the effective version each time before using the Website.

2. OUR CONTACTS

If you have any questions, comments or notices relating to this Policy or your privacy rights and data, or would like to communicate with us on any other issue relating to your Personal Data, please get in touch with us at (the “Contacts”):

Email:           [email protected]

Address:      IFZA Business Park, DDP, Office 53683-001, Dubai, UAE.

3. THE DATA TO WHICH THIS POLICY APPLIES
   • “Personal Data” includes any data or a combination of data that could directly or indirectly be used to identify you.
   • In some areas, certain types of the Personal Data might be deemed sensitive personal data (like precise geolocation data, biometric data, racial or ethnic origin, health information, or financial information). The definitions of personal data and sensitive personal data can vary by region. We do not knowingly collect data that is considered sensitive personal data. We also recommend you not share sensitive personal data with us, including by communicating with our employees or via any other communication tools, including, but not limited to, via the Website. However, if you share such sensitive personal data with us, you consent to us to process it under the terms and conditions of this Policy.
   • Please carefully read this Policy before sharing any information with us. By accessing and using the Website, you unconditionally consent to and accept all terms and conditions indicated in this Policy. Please do not share any information with us if you disagree with any terms and conditions indicated in this Policy or do not understand them. Please feel free to reach us at the Contacts indicated in Section 2 if you have any questions concerning the Policy.

4. WHERE DO WE GET YOUR PERSONAL DATA FROM?
   • This Policy applies to the Personal Data we collected through our Website, email, social media, or other legitimate sources.
   • We may also obtain the Personal Data about you from public sources or third parties, as allowed by and subject to applicable law, such as social networks, our affiliates, analytical sources, and advertising, as well as other legitimate sources.

5. LAWFUL BASIS TO PROCESS THE PERSONAL DATA
   • We process your Personal Data:

• At your direction and with your consent;
• To comply with the contractual oblgiations with you;
• To comply with the regulatory and legal requirements;
• To protect your legitimate interests;
• For scientific research purposes;
• For other legitimate business purposes.
  • Please note that you have choices about the Personal Data we collect from you. You may consent or decline when asked to provide the Personal Data. However, if you choose not to provide the Personal Data necessary to provide a product or service, you may not be able to use some of our features, products or services. 

6. THE PERSONAL DATA WE MAY COLLECT FROM YOU

We may collect the following Personal Data from you:

• Identity data, for example, name, ID, contact information (email, telephone number or physical address), account username, age, and gender.
• Client records, such as purchase history, billing and shipping information, payment information like your credit card number, other data about your transactions with us, content you upload to the Website or write in the chats or other communication tools you use with us.
• Contact data, such as address, telephone number, email or other details you provide to us, our employees, or our commercial partners and service providers as your contact detail.
• Marketing data, such as your preferences regarding marketing and advertising information you wish to receive from us.
• Public data, for example,  any Personal Data that is publicly available, such as information related to sanctions, watch lists, or credit status.
• Internet or Other Network Activity, for example, device identifier and operating system, browser information, IP address, Internet activity and social media activity, and activity at our Website.
• Interest data, for example, information on your hobbies, behaviour, or interests that you notify us about or that we assume based on your activity on the Website.
• Professional or Employment Data, for example, the Personal Data provided on a job application.

7. PURPOSE OF PROCESSING YOUR PERSONAL DATA

We may process your Personal Data for the following purposes:

• to enable you to use the Website, our products and services;
• to create and maintain your account on the Website (provide that the Website allows creating the account);
• to communicate with you on any matters relating to the Website, content placed on it, our products and services, your requests, marketing researches;
• to provide any products and services that you may request from us;
• to process your payments;
• to ensure the support and the products and services we offer to you are always at their best level and improve them, for which purpose we may keep record and store our communications between us and you made through any communication means;
• to assist third parties to provide service and support to you, such as banks, payment platforms, agents, brokers, etc.;
• to fulfil our contractual obligations to you;
• to provide you with advertising, marketing and promotion information, including on the products and services which may interest you;
• to maintain, upgrade and improve our Website from a technical standpoint to its their stable and proper functioning in your best interest;
• to monitor the way the Website is used to ensure compliance with laws and regulations and this Policy;
• to analyse the effectiveness of our work, services, statistics information, your advertising and consumer preferences;
• to advise you and provide information to you on the use of the Website;
• to store and share your information with other users on the Website, which you consent to display on the Website as publicly available;
• to protect your or our legitimate interests or the legitimate interests of other persons (for example, our users in case of infringement of their rights);
• to analyse, maintain and develop our business model;
• to share information with our existing or potential investors or purchasers of the shares in our companies;
• to comply with legal requirements and regulations. 

8. PERSONS WITH WHOM WE SHARE YOUR PERSONAL DATA

We disclose or transfer your Personal Data to our affiliates, employees, contractors, advisors, suppliers, business partners, service providers, state authorities, courts and other persons, provided that, however, such disclosure and transfer may only be made:

• on a need-to-know basis;
• for the purposes described in this Policy or notified to you when collecting your Personal Data;
• with all due actions, ensuring the protection and safety of your Personal Data by third parties.

9. COUNTRIES TO WHICH YOUR PERSONAL DATA MAY BE TRANSFERRED
   • Your Personal Data will be primarily stored, hosted, and processed in the United Arab Emirates. At the same time, we may transfer your Personal Data to other countries, for instance, to our contractors involved in the maintenance, support, development, and operation of the Website, or to other persons with whom we may share your Personal Data under this Policy, or to store the Personal Data on the servers located in other countries.
   • The country where your Personal Data may be transferred may have a different level of protection and regulation concerning personal data than in your country. However, we will perform all reasonable actions to ensure that your Personal Data is fully protected and secured in each country and that you can enjoy all your rights relating to your Personal Data without any restrictions and subject to the requirements of the applicable law.

10. HOW WE SECURE YOUR PERSONAL DATA
    • We maintain appropriate measures to protect the security  of  your Personal Data. In particular, we implement a variety of security measures to protect your personal information from unauthorised access, use, or disclosure. These measures include, among others, encryption of sensitive data during transmission, regular security assessments, access controls to limit who can access your information
    • However, despite all due effort, no data transmissions over the Internet can be guaranteed to be 100% secure due to the inherent risks of data transmission. Therefore, we cannot ensure or warrant the security of any data you transmit to us, and you understand that any data that you transfer to us is done at your own risk. We recommend that you also take additional measures to protect your Personal Data. For example, you may install anti-virus software, close browsers after use, always keep your login credentials and passwords confidential, and regularly update software and apps to ensure you have the latest security features. 
    • If we learn of a security system breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Website, or providing the Personal Data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Website. We may post a notice via our Website if a security breach occurs. We may also send an email to you at the email address you provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. If you have any questions on the security measures  we use, you may contact us using the contact indicated in Section 2 of this Policy. 

11. YOUR RIGHTS

We will respond to any rights request in accordance with local legal regulations. If you wish to make a request related to any of the rights set forth below, you may contact us using the Contacts indicated in Section 2 of this Policy. We may need to verify your request before completing it. For example, we may ask you to confirm data points we already have about you. We will only use Personal Data provided in a request to verify the requestor’s identity or authority.

Right to know or access

You may have the right to get confirmation about whether or not your Personal Data is being processed. If so, you may have the right to access the Personal Data and other information, such as the purposes, the categories of the Personal Data, the recipients (or categories of recipients) to whom the Personal Data have been or will be disclosed, etc. Where feasible and permitted by law, we will provide a copy of the Personal Data we are processing. If you make the request by electronic means, and unless otherwise requested, the data shall be provided in electronic form.

Right to correction, rectification, and completion

You may have the right to correct, rectify, or complete your Personal Data if inaccurate or incomplete.

Right to delete or erasure (‘right to be forgotten’)

You may have the right to delete or erasure your Personal Data in certain circumstances, including when:

• your Personal Data is no longer necessary for the purposes for which it was processed,
• you withdraw your consent on which the processing is based, and we have no other legal ground for the processing,
• you object to the processing, and there are no overriding legitimate grounds for the processing,
• your Personal Data have been unlawfully processed,
• your Personal Data must be erased for compliance with a legal obligation to which we are subject.

However, this right shall not apply to the extent that processing is necessary and lawful for certain purposes under the applicable law, such as compliance with a legal obligation which requires processing by a law to which we are subject, for the performance of a task carried out in the public interest, for reasons of public interest in the area of public safety, for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, for the establishment, exercise or defines of our legal claims.

Right to restriction of processing

You may have the right to restrict the processing for the following reasons:

• you contest the accuracy of your Personal Data for a period enabling us to verify the accuracy of the Personal Data,
• the processing is unlawful, and you oppose the erasure of the Personal Data and request the restriction of their use,
• you exercised your right to object to processing pending the verification of whether our legitimate grounds override yours.

Right to data portability

You may have the right to receive the Personal Data you have given us in a structured, commonly used and machine-readable format. You have the right to send that Personal Data to another controller if the processing is based on appropriate consent or contract and is carried out by automated means.

Right to object

You may have the right to object, on grounds relating to your particular situation, to processing your Personal Data, which is based on our legitimate purposes. We will stop processing Personal Data unless we have compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defence of legal claims. If Personal Data is processed for direct marketing purposes, including profiling, you may object at any time.

Right to opt-out of profiling and automated individual decision-making

You may have the right not to be subject to a decision based solely on automated processing, including profiling, except under certain exceptions under the applicable law.

Right to withdraw consent

Where the processing of the Personal Data is based on your consent, you may have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

Right to anonymity

You may also have a right to request anonymity. This means that your Personal Data would not be collected or processed. If you choose to exercise this right, we may not be able to provide you with the services you requested on the Website, or you may not be able to use all or some of the features on the Website.

Right to lodge a complaint with a supervisory authority

You may have the right to lodge a complaint with a supervisory authority.

Right to Non-Discrimination

You may have the right to non-discrimination and to receive equal service and pricing from a business even after exercising your rights.

Other rights

You may enjoy other rights relating to your Personal Data under the applicable law.  

12. THIRD-PARTY LINKS

Our Website may contain links to third-party websites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s website. We strongly advise you to review the privacy policy (or similar document regulating personal data processing) and terms of service of any third-party site you visit. We have no control over and assume no responsibility for content, privacy policies, or practices of any third-party sites or services.

13. CHILDREN’S PRIVACY

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information from our records.

14. COOKIES

Cookies are small text files that are placed on your device when you visit a website. They are widely used to make websites work more efficiently, as well as to provide information to the site owners.

Types of Cookies We Use

We use the following types of cookies on our Website:

• Essential Cookies. These cookies are necessary for the operation of our Website. They enable you to navigate them and use their features.
• Performance Cookies. These cookies collect information about how you use our Website, such as which pages you visit most often. This information helps us improve the performance of our Website.
• Functionality Cookies. These cookies allow our Website to remember choices you make and provide enhanced, more personalized features. For example, they may store your preferences regarding language or region.
• Marketing Cookies. These cookies are used to deliver advertisements relevant to you and your interests. They also help us measure the effectiveness of our advertising campaigns.

How You Can Manage Cookies

You can control the use of cookies at the individual browser level. If you prefer to prevent the use of cookies, you can adjust your browser settings to refuse cookies or to alert you when cookies are being sent. Please refer to your browser’s help section for instructions.

Third-Party Cookies

Our Website may also include cookies from third-party services that are used for analytics, advertising, and social media. These cookies are governed by the privacy policies of the third-party providers.