The Data Controller is Fortune 5 Investments, with its registered office located in office 2801, Boulevard Plaza Tower 1, Downtown, Dubai, UAE.
Fortune 5 Investments is registered in the UAE.
Our primary goal in collecting personal data from you is to give you an enjoyable customized experience whilst allowing us to provide services and features that most likely meet your needs.
Please note that we do not intend to collect any personal data from children under thirteen years of age and no child under thirteen should submit any personal data to any of the Sites. Should we discover that any such personal data has been delivered to any of the Sites, we will remove that information as soon as possible.
2.1 Customer services and administration
We collect certain personal data from you such as your name, job title, work and/or home address, company, company size, job function and/or seniority, industry, qualification levels, and telephone number and email address, in order to register you for access to certain content and subscriptions. This information may be supplemented with demographic information from your use of our Sites such as your location, age, gender, purchasing preferences and interests.
This information is used to administer and deliver to you the products and/or services you have requested, to operate our Sites efficiently and improve our service to you, and to retain records of our business transactions and communications. By using the Sites and submitting personal information through the registration process you are agreeing and have given us consent that we may collect, hold, process and use your information (including personal information) for the purpose of providing you with the Site services and developing our business, which shall include (without limitation) the purposes described below in and in accordance with the GDPR. We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. We are required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
2.2 Monitoring the use of our Sites
If, as part of our Site services, we enable you to post information or materials on our Site, we may access and monitor any information which you upload or input, including in any password-protected sections. Subject to any necessary consents, we also monitor and/or record the different Sites you visit and actions taken on those Sites, e.g. content viewed or searched for.
If you are a registered user (e.g. a subscriber or taking a trial), when you log on, this places a cookie on your machine. This enables your access to content and services that are not publicly available. Once you are logged on, the actions you take – for example, viewing an article – will be recorded (subject to any necessary consents). We may use technology or a service provider to do this for us. This information may be used for one or more of the following purposes:
– to fulfil our obligations to you;
– to improve the efficiency, quality and design of our Sites and services;
– to see which articles, features and services are most read and used
– to track compliance with our terms and conditions of use;
– for marketing purposes (subject to your rights to opt-in and opt-out of receiving certain marketing communications) – see paragraph 5 below;
– for advertising purposes, although the information used for these purposes does not identify you personally;
– to protect or comply with our legal rights and obligations; and
– to enable our employees to contact and interact with you online in connection with any content you may have viewed in our Sites.
Please see paragraph 3 below for more information on cookies and similar technologies and a link to a page where you can turn them on or off.
Some of your personal data collected, in accordance with the privacy notice, may be used by us and/or our other group companies and third party service providers to contact you by email, fax, telephone and/or post for sending information or promotional material on our products and/or services and/or those of our other group companies.
We give you the opportunity to opt-out of receiving marketing communications and will in certain circumstances need to obtain your consent before sending such communications to you. Further detail can be found on the applicable site and in each marketing, communication sent by us, our group companies or service providers. See also “Consents and opt-outs” section below.
What is a cookie?
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your desktop, tablet or smartphone when you first visit our Sites. The cookie will help our Sites, or another website, recognize your desktop, tablet or smartphone the next time you visit. A cookie can contain Personal Information. We detail what cookies we use, and what information they contain, below.
What types of cookies do we use?
We use the following cookies:
• Strictly necessary cookies: These are the cookies required to operate our Sites (for example, to enable you to move around our Sites and use some of their features).
• Analytics cookies: These allow us to recognize and count the number of visitors and to see how visitors move around our Sites. This helps us improve the design of our Sites.
• Functionality cookies: These are used to recognize you when you return to our Sites. This enables us to personalize our content for you and remember your preferences.
• Targeting cookies: These cookies record your visit to our Sites, the pages you visited and the links you followed. We use this information to provide you with targeted advertising and content we think you will be interested in.
In some cases, we may use information from third party cookies (be they analytics, functionality or targeting cookies) to help us with market research or improving the design of our Sites (for example, where traffic to our Sites comes from).
How can I block cookies?
You can block cookies by activating the setting on your browser that allows you to refuse all, or some, cookies. If you block all cookies (including essential cookies) you may find that parts of our Sites do not work properly, or you may not be able to access our Sites at all.
When do cookies stop?
Our cookies expire after up to two years.
Email tracking: So that we can better understand our users’ needs, we track responses to our emails – for example, to see which links are the most popular in newsletters, and to log and follow up responses to our marketing messages. To do this, we use small image files that are placed within the body of our email messages. They enable us to tell if a message has been opened and to track click-throughs on links within the message.
Any other purposes for which we wish to use your personal data will be notified to you and your personal data will not be used for any such purpose without obtaining your prior consent.
We may pass your personal data on to third-party service providers contracted to us in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service that they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with our procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for us to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by emailing email@example.com.
For turning cookies off, see the information in paragraph 3 above.
Information collected may be shared between with any of our group companies for the purposes listed above and as part of the processing activities.
We may also disclose your personal data to other third parties, including, without limitation, professional advisers, or governmental or State institutions or regulatory authorities, where necessary in order to exercise or defend legal rights or where required by law.
We may transfer, sell or assign any of the information described in this policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganization of our business.
Some of our Sites make message boards, blogs or other facilities for user generated content available and users can participate in these facilities. Any information that is disclosed in these areas becomes public information and you should always be careful when deciding to disclose your personal information.
Services on the Internet are accessible globally so collection and transmission of personal data is not always limited to one country. We may transfer your personal data, for the purposes listed above, to other group companies, service providers or other third parties which may be located in countries outside the European Economic Area, whose laws may not give the level of protection to personal data as within the UK. Where we conduct any transfers, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this
We are committed to keeping the data you provide us secure and will take reasonable precautions to protect your personal data from loss, misuse or alteration.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:
– unauthorized access
– improper use or disclosure
– unauthorized modification
– unlawful destruction or accidental loss
All our employees, contractors and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of your personal data, are obliged to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for us.
At your request, we can confirm what information we hold about you and how it is processed. If we do hold personal data about you, you can request the following information:
– Identity and the contact details of the person or organization that has determined how and why to process your data. In some cases, this will be a representative in the EU or UK.
– Contact details of the data protection officer, where applicable.
– The purpose of the processing as well as the legal basis for processing.
– If the processing is based on the legitimate interests of us or a third party, information about those interests.
– The categories of personal data collected, stored and processed.
– Recipient(s) or categories of recipients that the data is/will be disclosed to.
– If we intend to transfer the personal data to a third country or international organization, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
– How long the data will be stored.
– Details of your rights to correct, erase, restrict or object to such processing.
– Information about your right to withdraw consent at any time.
– How to lodge a complaint with the supervisory authority.
– Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
– The source of personal data if it wasn’t collected directly from you.
– Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
Upon request, we will provide you with a readable copy of the personal data which we keep about you. We may require proof of your identity.
We will allow you to challenge the data that we hold about you and, where appropriate in accordance with applicable laws, you may have your personal information:
– rectified or amended; and/or
We will occasionally update this privacy notice to reflect new legislation or industry practice, group company changes and customer feedback. We encourage you to review this privacy notice periodically to be informed of how we are protecting your personal data.
Issue 24 May 2018