We are committed to safeguarding the privacy of [our website visitors and service
users].
This policy applies where we are acting as a data controller with respect to the
personal data of [our website visitors and service users]; in other words where we
determine the purposes and the means of the processing of that personal data.
We use cookies on our website. Insofar as those cookies are not strictly necessary for
the provision of [our website and services], we will ask you to consent to our use of
cookies when you first visit the website.
Our website incorporates privacy controls which affect how we will process your personal
data. By using the privacy controls, you can [specify whether you would like to receive
direct marketing communications and limit the publication of your information]. You can
access the privacy controls via URL here.
In this policy “we”, “us”, and “our” refer to
ServizNow LLC. [For more information about us, see URL of about us section.
2. How we use your personal data
In this section 2 we have set out
The general categories of personal data that we may process;
[In the case of personal data that we did not obtain directly from you, the source and specific
categories of that data];
The purposes for which we may process personal data; and
The legal bases of the processing.
We may process [data about your use of our website and services] (“usage
data”). The usage data may include [your IP address, geographical
location, browser type and version, operating system, referral source, length of visit,
page views and website navigation paths, as well as information about the timing,
frequency and pattern of your service use.] The source of the usage data is [our
analytics tracking system]. This usage data may be processed [for the purpose of
analysing the use of the website and services]. The legal basis for the processing is
[consent] OR [our legitimate interest, mainly monitoring and improving our website and
services]].
We may process [your account data] (“account data”). [ The
account data may [include your name and email address].] [The source of the account data
is [you or your employer].] The account data may be processed [for the purposes of
operating our website, providing our services, ensuring the security of our website and
services, maintaining back-ups of our databases and communicating with you.] The legal
basis for this processing is [consent] OR [our legitimate interests, namely [the proper
administration of our website and business]] OR [the performance of a contract between
you and us and/or taking steps, at your request, to enter into such a contract].
We may process [your information included in your personal profile on our website] (“profile
data”). [The profile data may include [Your name, address, telephone
number, email address, profile pictures, gender, date of birth, relationship status,
interests and hobbies, educational details and employment details].] The profile data
may be processed for [the purposes of enabling and monitoring your use of our website
and services]. The legal basis for this processing is [consent] OR [our legitimate
interests, namely [the proper administration of our website and business]] OR [the
performance of a contract between you and us and/or taking steps, at your request, to
enter into such a contract].
We may process [your personal data that are provided in the course of the use of our
services] (“service data”). [ The service data may [include
your work timings, rate per visit or hourly rate, delivery charges and others].] [The
source of the service data is [you or your employer].] The service data may be processed
[for the purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our databases and
communicating with you.] The legal basis for this processing is [consent] OR [our
legitimate interests, namely [the proper administration of our website and business]] OR
[the performance of a contract between you and us and/or taking steps, at your request,
to enter into such a contract].
We may process [information that you post for publication on our website or through our
services] (“publication data”). The publication data may be
processed [for the purposes of enabling such services and administering our website and
services.] The legal basis for this processing is [consent] OR [our legitimate
interests, namely [the proper administration of our website and business]] OR [the
performance of a contract between you and us and/or taking steps, at your request, to
enter into such a contract].
We may process [information contained in any enquiry you submit to us regarding goods
and/or services] (“enquiry data”). The enquiry data may be
processed [for the purposes of offering, marketing and selling relevant goods and/or
services to you.] The legal basis for this processing is [consent].
We may process [information relating to our customer relationships, including customer
contact information] (“customer relationship data”). [The
customer relationship data may include [Your name, your employer, your job title or
role, your contact details and information contained in communications between us and
you or your employer].][The source of the customer relationship data is [you or your
employer].] The customer relationship data may be processed for [the purposes of
managing our relationships with customers, communicating with customers, keeping record
of those communications and promoting our products and services to customers]. The legal
basis for this processing is [consent] OR [our legitimate interests, namely [the proper
management of our customer relationships]].
We may process [information relating to transactions, including purchases of goods and
services, that you enter into with us and/or through our website] (“transaction
data”). [The transaction data may include [Your contact details, your
card details, and the transaction details].] [The transaction data may be processed for
[the purpose of supplying the purchased goods and services and keeping proper records of
those transactions]. The legal basis for this processing is [the performance of a
contract between you and us and/or taking steps, at your request, to enter into such a
contract and our legitimate interests, namely [the proper administration of our website
and business]].
We may process [information that you provide to us for the purpose of subscribing to our
email notifications and/or newsletters] (“notification data”).
[The notification data may be processed for [the purposes of sending you the relevant
notifications and/or newsletters]. The legal basis for this processing is [consent] OR
[the performance of a contract between you and us and/or taking steps, at your request,
to enter into such a contract].
We may process [information contained in or relating to any communication that you send
to us] (“correspondence data”). [The correspondence data
may include [the communication content and metadata associated with the communication].
[Our website will generate the metadata associated with communications made using the
website contact forms.] The correspondence data may be processed [for the purposes of
communicating with you and record-keeping]. The legal basis for this processing is [our
legitimate interests, namely [the proper administration of our website and business and
communications with users]].
We may process [any of your personal data identified in this policy] where necessary for
[the establishment, exercise, or defence of legal claims, whether in court proceedings
or in an administrative or out-of-court procedure]. The legal basis for this processing
is our legitimate interests, namely [the protection and assertion of our legal rights,
your legal rights and the legal rights of others].
We may process [any of your personal data identified in this policy] where necessary for
[the purposes of obtaining or maintaining insurance coverage, managing risks, or
obtaining professional advice]. The legal basis for this processing is our legitimate
interests, namely [the proper protection of our business against risks].
In addition to the specific purposes for which we may process your personal data set out
in this Section 2, we may also process [any of your personal data] where such processing
is necessary [for compliance with a legal obligation to which we are subject, or] in
order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you
to do so.
3. Automated Decision Making
We will use your personal data for the purposes of automated decision-making in relation
to providing access and delivering services through our platform.
This automated decision making will involve search engine using your mobile number or
email id, we use your first name and last name, mobile number and/or e-mail address to
identify you as a user and provide access to our Platform.
The significance and possible consequences of this automated decision-making are
delivering our Services to you in accordance with our Terms of Use, to make suggestions
and recommendations to you about our Services that may be of interest to you,
undertaking marketing activities to offer you Services that may be of your interest.
4. Providing your personal data to others
We may disclose [your personal data] to any member of our group of companies (this means
our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as
reasonably necessary for the purposes, and on the legal bases, set out in this policy.
We may disclose [your personal data] to [our insurers and/or professional advisors]
insofar as reasonably necessary for the purposes of [the establishment, exercise, or
defence of legal claims, whether in court proceedings or in an administrative or
out-of-court procedure].
We may disclose [your personal data] to [our suppliers or subcontractors] insofar as
reasonably necessary for the purposes, and on the legal bases, set out in this policy
Financial transactions relating to [our website and services] [are] or [may be] handled
by our payment services providers. We will share transaction data with our payment
services providers only to the extent necessary for the purposes of [processing your
payments, refunding such payments and dealing with complaints and queries relating to
such payments and refunds].
We may disclose [your enquiry data] to [one or more of those selected third party
suppliers of goods and services identified on our website] for the purpose of [enabling
them to contact you so that they can offer, market and sell to you relevant goods and/or
services].[Each such third party will act as a data controller in relation to the
enquiry data that we supply to it; and upon contacting you, each such third party will
supply to you a copy of its own privacy policy, which will govern that third party’s
use of your personal data.]
In addition to the specific disclosures of personal data set out in this section 4, we
may disclose your personal data where such disclosure is necessary for compliance with a
legal obligation to which we are subject, or in order to protect your vital interests or
the vital interests of another natural person. [ We may also disclose your personal data
where such disclosure is necessary for the establishment, exercise, or defence of legal
claims, whether in court proceedings or in an administrative or out-of-court procedure.]
5. International transfers of your personal data
In this section 5, we provide information about the circumstances in which your personal
data may be transferred to third parties inside and outside of the UAE.
To the extent that the GDPR applies to our relationship with you, then whenever we
transfer your personal data out of the EEA or UAE, we ensure a similar degree of
protection is afforded to it by ensuring at least one of the following safeguards is
implemented:
Where we transfer your personal data to countries that have not been deemed to provide an
adequate level of protection for personal data by the European Commission we will ensure that
adequate safeguards are put in place, such as specific contract clauses that have been approved
by the European Commission for use with third parties, which give personal data the same
protection it has in the European Union. For further details, see European
Commission: Model contracts for the transfer of personal data to third countries.
Where appropriate we may need to rely upon other derogations under the GDPR that allow for
transfers out of the EEA to countries that are not deemed to provide adequate levels of
protection or were we do not have adequate safeguards. For further details please see European
Commission : Working Party 29 Guidelines on Article 49 GDPR Derogations.
Where we use service providers based in the US, we may transfer data to them if they are part of
the Privacy Shield which requires them to provide similar protection to personal data shared
between the Europe and the US. For further details, see European
Commission: EU-US Privacy Shield.
You acknowledge that [personal data that you submit for publication through our website
or services] may be available, via the internet, around the world. We cannot prevent the
use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
This Section 6 sets out our data retention policies and procedure, which are designed to
help ensure that we comply with our legal obligations in relation to the retention and
deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer
than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
[personal data category or categories] will be retained for a minimum period of 10
years, following 4/10/2019, and for a maximum period of 50 years, following 4/10/2019.
In some cases, it is not possible for us to specify in advance the periods for which
your personal data will be retained. In such cases, we will determine the period based
on your business relationship standing with us.
Notwithstanding the other provisions of this section 6, we may retain your personal data
where such retention is necessary for compliance with a legal obligation to which we are
subject, in order to protect your vital interests or the vital interests of another
natural person.
7. Security of personal data
We will take appropriate technical and organizational precautions to secure your
personal data and to prevent the loss, misuse or alteration of your personal data.
We will store [all your personal data] on [secure servers, personal computers and mobile
devices, and in secure manual record-keeping systems].
The following personal data will be stored by us in encrypted form: [your name, contact
information, password(s) and cardholder data].
Data [relating to [your enquiries and financial transactions]] that is sent from your
web browser to our web server, or from our web server to your web browser, will be
protected using encryption technology.
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data
over the internet is inherently insecure, and we cannot guarantee the security of data
sent over the internet.
You should ensure that your password is not susceptible to being guessed, whether by a
person or a computer program. You are responsible for keeping the password you use for
accessing our website confidential and we will not ask you for your password (except
when you log in to our website).
8. Amendments
We may update this policy from time to time by publishing a new version on our
website.
You should check this page occasionally to ensure that you are happy with any changes to
this policy.
We may or will notify you of changes or significant changes to this policy by email or
through the private messaging system on our website.
9. Your rights
In this section 9, we have summarized the rights that you have under data protection
law. Some of the rights are complex, and not all the details have been included in our
summaries. Accordingly, you should read the relevant laws and guidance from the
regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
The right to access;
The right to rectification;
The right to erase;
The right to restrict processing;
The right to object to processing;
The right to data portability;
The right to complain to a supervisory authority; and
The right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data
and, where we do, access to the personal data, together with certain additional
information. That additional information includes details of the purposes of the
processing, the categories of the personal data concerned and the recipients of the
personal data. Providing the rights and freedoms of others are not affected, we will
supply to you a copy of your personal data.
To lodge a complaint at any time with your local supervisory responsible for you as
outlined in section 13. However, before you make a complaint to the data protection
authority, we would appreciate the chance to deal with your concerns in the first
instance, please reach out to our Privacy Officer at info@serviznow.ae.
10. Third-Party Websites
Our Platform may contain links to third party websites or apps. If you click on one of
these links, please note that each one will have its own privacy policy. We do not
control these websites/apps and are not responsible for those policies. When you leave
our Platform, we encourage you to read the privacy notice of every website you visit.
11. Personal Data of Children
Our Services are not intended for children under 16 and we do not knowingly collect data
from anyone under 16. If we become aware that a person under 16 has provided us with
personal data, we will delete it immediately.
If you are resident in the UAE and under 21, we are not permitted to contract with you
directly. If you are a resident in the UAE and under 21 then, by agreeing to this
Privacy Policy, you acknowledge and agree that your guardian has read and consented to
its terms on your behalf. If we seek your consent to process your personal data for a
specific purpose in accordance with this Privacy Policy, consent must be granted on your
behalf by your guardian.
12. Updating information
You may update your personal information by logging into the Website. You may also
email
us at info@serviznow.aein order to
access,
correct, delete or update your personal information on our systems. We will answer
every
email as promptly as possible.
13. Acting as a data processor
ServizNow is the data controller for the processing of your personal data via the
website serviznow.ae of ServizNow.
Be aware that ServizNow will only be the data controller for the processing of
personal
data for its own purposes, such as the processing of personal data of our
(potential)
customers in relation to sales, service delivery, invoicing, customer relationship
management and direct marketing.
On the other hand, if you are a visitor of one of our service providers, our service
provider will be the ‘data controller’ and ServizNow will be acting as
our
service provider’s ‘data processor’. In such case, our
service
provider is the one assuming responsibility for the processing of personal data
through
our services.
14. Our Details
The full name of our company is ServizNow LLC. We are registered in Fujairah under registration number 11405/2017.
