Data Protection Regulation
Effective date: 1st January 2020.
It is a priority goal for Neogon Holding FZE. (hereinafter: the Provider) and a commitment to protect personal data provided by visitors.
The Provider as data processor hereby informs the visitors of www.neogonholding.com (hereinafter: Website) about the personal data managed in connection with the operation and services of the websites, the identity and data of data processor(s), its principles and practice adopted in respect of the management of personal data, data forwarding, organisational and technical measures taken to protect personal data, and the modes and possibilities those involved can practice their rights.
This Data Management Information is part of the Conditions of Use and is to be interpreted together with its provisions.
We are confident that you will find the information that you need set out in this policy, but if you need to know more about the data that we hold or the way that we use it, you can contact us by emailing info@neogonholding.com or by post at Neogon Holding FZE, . Business Center, AI Shmookh Building, UAQ Free Trade Zone, Umm AL Quwain, U.A.E.
This policy (together with the Conditions of Use) describes the data that we collect from you or about you, and the way that we use it. Please read the policy carefully as it will help you to understand the way that we use your data and our reasons for doing so.
The purpose of this Policy is to ensure that all services provided by the Provider to all individuals, regardless of their nationality or place of residence, are assured that their rights and fundamental freedoms, in particular their privacy, are respected in the processing of their personal data (data protection).
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1. Data, contact options of the data processor
Name: Neogon Holding FZE. (hereinafter: ‘provider’)
Registered office: Business Center, AI Shmookh Building, UAQ Free Trade Zone, Umm AL Quwain, U.A.E.
Licence Number: 5520
Tax number: 100552824300003
Contact: info@neogonholding.com
Website: www.neogonholding.com (hereinafter: ‘website’)
Confidential management of the personal data of the User is a priority requirement, so the Provider does not disclose the personal data of the User to third parties, and only makes it accessible for the authorities within the limits of the relevant legal regulations.
The Provider does not use the services of external data processors. The company itself processes the Personal data it manages.
2. Legal basis of Data management
Data processing is done based on the willing statement of the Users of the internet content on the website, based on sufficient information; said statement contains the express consent of the Users to the use of their Personal data provided in the course of using the site. The legal basis for data management is the wiling consent of the person involved, based on Freedom of Information Act 2000. The purpose of data management is to ensure the provision of services accessible under the URL neogonholding.com. The range of Personal data to be provided as necessary to use these services is in the description of the relevant services. The purpose of automatically recorded data is making statistics, technical development of the IT system, the protection of the rights of the users. The Data processor cannot use the provided Personal data for any purpose other than what is specified in these items. Disclosure of Personal data for third parties or authorities – if no legal regulation provides otherwise with mandatory effect – is only possible with the previous express consent of the User. The Data processor does not check the Personal data provided for it. Only the person providing the data is responsible for the accuracy of the data. Any User, when providing his/her e-mail address also accepts the responsibility that only he/she uses the services of the given e-mail address. Considering this responsibility any responsibility in connection with logging in from a given e-mail address is the burden of only the user who registered the e-mail address. The User guarantees that he/she legally obtained the consent of those involved for the management of the personal data of natural third parties that was disclosed and made accessible in the course of using the service.
In lieu of any legal provision providing otherwise the Provider can manage the registered personal data without any further express consent and after the consent of the User is revoked if it is to perform the legal obligations of the Provider (especially the accounting obligation and the contractual obligation towards the Partners) and to enforce the legal interests of its own or of third parties, if this enforcement of interests is proportionate to the limitations on the right to protect personal data.
The Provider manages the registered personal data in accordance with the established, effective data protection regulations, the international agreements, Union law acts concerning data protection, and other relevant legal regulations, according to this information page. .
3. Range of managed data
Only the User is responsible for the reality, accuracy of the personal data.
The character of the Services and the electronic trade, accounting and advertisement regulations influence and partly define the range of managed personal data, especially the Electronic Commerce (EC Directive) Regulations 2002 and the Directive 2000/31/EC of the European Parliament and of the Council of 8 June 2000 on certain legal aspects of information society services, in particular electronic commerce, in the Internal Market (Directive on electronic commerce) and The Business Protection from Misleading Marketing Regulations 2008. The Provider performs the data collection in full compliance with the rules prescribed by the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) an in the United Arab Emirates the Federal Law No. 5 of 2012 on Combatting Cybercrimes, the Federal Law No. 5 of 1985 (the “Civil Code”), the Federal Law No. 3 1987 (the “Penal Code”) and Federal Law No. 1 of 2006 and its corresponding Dubai Law No. 2 of 2002 relating to Electronic Transactions and Commerce (“ETCL”).
Data processed in the course of providing services: first name, last name, contact phone number, e-mail address.
Our Services are not intended for children under 18 and we do not knowingly collect data from anyone under 18. If we become aware that a person under 18 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.
Data processed by Neogon Holding FZE in the course of inquiry with direct business and marketing purposes with advertisement content: First and last name of User, contact phone number, e-mail address.
E-mails and Newsletters
The Service Provider shall pay particular attention to the legality of the use of the e-mail addresses it manages, so use it only as specified below (for information or advertisement) to send an e-mail.
Managing e-mail addresses primarily serves to identify the Customer, to execute orders, to access the Services, so that e-mails are sent primarily for this purpose.
Letters of advertising or advertising (newsletters) to e-mail addresses given during the registration will be sent by the Service Provider only with the express consent of the User, in the cases and in the manner prescribed by law. The newsletter contains direct marketing elements and promotional items. The Service Provider handles the information provided by the User during the use of the newsletter.
In the case of a newsletter, the Service Provider will handle the information provided during the subscription of the Affected Newsletter until the Relevant has subscribed to the newsletter by clicking on the “Unsubscribe” button at the bottom of the newsletter or requesting it to be removed from the subscribers list by email or by post. In the event of unsubscribe, the Service Provider will not contact the User with any further newsletters or offers. The User can unsubscribe at any time from the newsletter and revoke his or her consent. Our registered users can sign up for their newsletter at any time and free of charge on their personal site.
4. Purpose of data management
The purpose of the management of the personal data of the User is provision of the Services of the Website, in this respect especially: identifying Users, differentiating them from the other Users, preventing unauthorised parties from accessing personal data; forwarding the data of the User for calls for offers, identifying entitlements of the User (partial services that can be used by the User); administration through the customer service of the Service; contacting the User; sending system messages in connection with the Service; providing storage capacity to publish User Content (e.g. comments); improvement of the services of the Website, improving its standards, enhancing user experience; avoiding abuse; performance of accounting obligations; performance of legal obligations towards the Partners.
Based on an express consent the Provider can use personal data of the User for the purposes of direct marketing or marketing with advertisement content (e.g. Neogon Newsletter, e-DM, etc.).
5. Time of data management
Management of Personal data provided by the User remains until the User unsubscribes from the service with the provided e-mail address. The date of deletion is the 10th working day from the reception of the request for unsubscribing (request for deletion). In case of using illegal, deceptive Personal data or in case of criminal acts committed by the User or in case of attacks against the system the Data processor is entitled to immediately delete the data of the User together with terminating the registration of the User; however, the Data processor is also obliged to keep the Personal data for the duration of the procedure to be conducted in case of a suspected criminal act or civil law responsibility. Personal data provided by the User can be managed by the Provider as Data processor – even in case the User does not unsubscribe from the service – until the User expressly requests the termination of the management of the same in writing. The request of the User to terminate the Data management without unsubscribing from the service does not concern its right to use the service; however, it can happen that without Personal data the User cannot use certain services. Deletion of the Personal data is done within 10 working days from the reception of the request for the deletion. Data that is automatically, technically being recorded in the course of the operation of the system will be stored, in the system for the period that is reasonable from the perspective of securing the operation of the system from the time the data is generated. The Provider guarantees that this automatically recorded data cannot be connected to other Personal data of the User with the exception of cases made mandatory by legal regulations. If the User terminated his/her consent given for the management of his/her Personal data, or unsubscribed from the service, then after this his/her person cannot be identified from the technical data.
6. The rights of the users concerning their personal data managed by the data processor
Users can request information about the management of their personal data from the Provider as Data processor at any time, in writing, in a letter sent to the address of the Data processor in registered mail or receipted-registered mail, or by e-mail sent to the address info@neogonholding.com. The Data processor only considers the request for information sent by e-mail valid if it was sent from an e-mail address belonging to an already existing User in our system. The request for information can extend to the data of the users that the data processor manages, the source of the data, the purpose of data management, its legal basis, duration, the name and address of possible data processors, activities in connection with Data management, and who or for what purpose received or shall receive the data of the User in case of forwarded Personal data. The Data processor is obliged to provide information concerning the questions about Data management as soon as possible after receiving the request, but within 30 days at the most in writing. In case of e-mail the first working day following the day of sending the e-mail must be considered to be the day of reception.
You may have certain legal rights regarding your personal data depending on the country you are in or how we interact with you. You can learn more about this in this section.
6.1. United Arab Emirates (“UAE”) data subjects
If you are a data subject in the UAE, you will have the following rights:
- Right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Right to request correction of any of the data we have about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Right to withdraw your consent to the processing of your personal data at any time. This does not affect the legality of any processing we have already carried out based on the consent given previously.
6.2. EU General Data Protection Regulation (“GDPR”) data subjects
If you are a data subject under the GDPR, you will have certain additional rights in relation to our handing of your personal information.
- Right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Right to request correction of any of the data we have about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Right to withdraw your consent to the processing of your personal data at any time. This does not affect the legality of any processing we have already carried out based on the consent given previously.
- Right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
- Right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Right to request for the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Disposal of personal data
Changes in personal data or a request for the deletion of Personal data can be sent as an express, written statement in a letter sent using the internal mailing system of the service. Sending newsletters can be unsubscribed from with the help of the link ‘unsubscribe from newsletter’ at the bottom of the newsletter. After the performance of a request for the deletion or modification of personal data the former (deleted) data cannot be restored.
8. Use of Cookies
In addition to personal information you provide, we may also collect information about you automatically when you visit the Site or access content in our electronic communications with you. Range of concerned persons: all of the Site’s visitors.
The collection of information may involve the use of cookies and web beacons. A web beacon is a small graphic image placed on a web page that is designed to allow us to monitor traffic on the Site or within electronic communications. A cookie is a small text file that is placed on your computer’s hard drive by your browser. Cookies allow us to identify your computer and find out details about your visit and browsing habits so that we can offer you a more personalised experience and manage, monitor and improve services. Most internet browsers accept cookies automatically, but usually you can alter the settings of your browser to erase cookies or prevent automatic acceptance if you prefer. If you choose not to receive our cookies, you may not be able to use some of the core features of the Site. The information collected by cookies and web beacons is not tied to your contact details (such as your name or email address), it only includes general information about your computer settings, your connection to the internet e.g. operating system and platform, IP address, your browsing patterns and timings of browsing on the Site and geographical location.
You can learn more about cookies and how to reject cookies using different types of browser by visiting http://www.allaboutcookies.org.
Display advertising on the Site is provided by our advertising partners. Our advertising partners will serve advertisements that they believe are most likely to be of interest to you, based on information about your visit to the Site and other websites (this information does not include your name, street address, email address or telephone number). For more information about this type of online behavioural advertising please visit http://www.youronlinechoices.com/.
Separate tools are also available for managing local shared objects or ‘Flash cookies’ from the Adobe website. These cookies may be used to manage the effective delivery of services using video or other flash related content.
9. Other Provisions
9.1. The Service Provider may collect data about the Activity of the Users that can not be linked to the other data provided by the User upon registration or any other data generated by the use of other websites or services.
9.2. In all cases where the Service Provider intends to use the provided data for purposes other than the purpose of the original data collection, he or she shall inform the Affected Person by means of which he or she shall obtain a prior express consent or provide him with an opportunity to prohibit the use.
9.3. The Service Provider undertakes to ensure the security of the data and also to take technical measures to ensure that the data that are recorded, stored or managed is protected and that it does everything in its power to prevent their destruction, unauthorized use and unauthorized alteration. Service Provider also agree that any third party to which the data may be transmitted or handed over also calls for compliance with this obligation.
9.4. The Service Provider reserves the right to unilaterally modify this Policy by prior notification of the Users. Upon the entry into force of this amendment, the Users are required to accept the changes in order to continue to use the Website .
