What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address.
What is Special Category Data?
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing.
What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Responsible for data processing
Responsible for data processing is Bellure media FZE LLC of Business Centre,Sharjah, Publishing City Free Zone, Sharjah, United Arab Emirates (“Bellure media FZE”, “we”, “us” or “our”). If you have any questions or if you wish to exercise your rights, please contact us using our Contact Form.
The Legal Bases for processing Personal Data
In accordance with the above-mentioned laws, we have to have at least one of the following legal bases to process your Personal Data:
Where is your data stored?
In the course of our business and service operations, we process data. All data collected is generally processed in our UAE location and our webhost Hostnet.nl who processes all data to be processed in connection with the operation of this website and your email exchanges with Issy on their EU based servers. The legal basis for the data processing is our legitimate interest in providing our website and services.
How long is your data stored?
We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists (in particular the UAE’s commercial and tax law for up to 5 years). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
Data we collect automatically
Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user’s device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.
To provide our website, we use the services of Hostnet.nl who processes all data to be processed in connection with the operation of this website and your email exchanges with Issy, on our behalf. The legal basis is our legitimate interest.
Data we collect from you directly
If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations and/or our overriding legitimate interest in processing your request.
When using our services
We process the data of our Service users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further.
Some of the Personal Data you provide may be considered “special” or “sensitive”. This includes Personal Data concerning for example your health, racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data.
You have choices about the Personal Data you provide during the Chat with Issy and how you share it. You don’t have to provide Personal Data or Special Category Data; however, information about you helps you to get more from our Services. It’s your choice whether to include Personal Data or Special Category Data and to make that information available to Issy during the Chat and Conversations. Please do not share information that you would not want to be available.
The legal basis for the processing of your personal and Special Category Data is the establishment and implementation of the user contract for the use of the service as well as your consent.
You may withdraw your consent and request us to stop using and/or disclosing your personal and Special Category Data by submitting your request to us.
The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent.
We also use Zoom (Zoom Video Communications, Inc.) to conduct online meetings, on-boarding measures and to provide our Chat services. When using Zoom various types of data are processed. The scope of the data depends on the information you provide before or during the online meeting. The processing bases are your consent as well as our legitimate interest.
Capturing audio and video during our lessons
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services.
Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Our Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.
Obligation to provide Personal Data
You are not obliged to provide us with Personal Data. However, depending on the individual case as described above, the provision of certain Personal Data may be necessary for the provision of the services. If you do not provide us with this Personal Data, we may not be able to provide the requested service.
Persons under the age of 18 should not transmit any Personal Data to us without the consent of their parents or legal guardians. We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
Automated decision-making including profiling does not take place.
Do Not Sell
We do not sell your Personal Data.
We are present on social media (currently, Twitter, Facebook and YouTube) on the basis of our legitimate interest. If you contact, connect or otherwise interact with us via social media, we and the relevant social media platform we are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis for the use of the relevant social media platform is our legitimate interest, your consent or, in the case of a (pre) contractual relationship with us, the initiation of a contractual service, if any.
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or the disclosure of data is permitted by relevant legal provisions.
In addition, we may disclose your Personal Data: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation; if Bellure media FZE (or a part of Bellure media FZE) is sold to or merged with another company; or if we have reason to believe that disclosure is necessary to protect Bellure media FZE, its users or the public.
In all cases other than those described above, Personal Data will not be disclosed by us to third parties for their own marketing purposes without your consent.
In the course of our business, we process data. This also includes disclosure by transmission to third parties and, where applicable, to so-called third countries outside the UAE and the EEA. Where we transfer data outside the UAE and the EEA, we ensure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.
Our data processing is subject to the principle that we only process the Personal Data that is necessary for the use of our services. In doing so, we take great care to ensure that your privacy and the confidentiality of all Personal Data are always guaranteed.
We also use technical and organizational security measures (TOMs) throughout the company to protect the data we manage from you against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.
Nonetheless, databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.
Your Rights and Privileges
Under the Law No. 45 and EU`s GDPR, you can exercise the following rights:
If you wish to exercise any of your rights, please contact us.
Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).
Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UAE is: The UAE Data Office, (https://u.ae/).
Updates and Questions
What are cookies?
Cookies are small pieces of text sent by your web browser from a website you visit. A cookie file is stored in your web browser and allows the website or a third-party service provider to recognise you and make your next visit easier and the website more useful to you. Cookies are essentially a user identification card for a website’s server.
Web beacons are small graphic files linked to our servers that allow us to track your use of our website and related features. Cookies and web beacons allow us to serve you better and more efficiently and to personalize your experience on our website.
Cookies can be “persistent” or “session” cookies.
We use both session and persistent cookies on our website, and we use different types of cookies to operate our website:
Necessary for the operation of our website. We may use essential cookies to authenticate users, prevent fraudulent use of user accounts or provide website functionality.
Enable us to recognise and count the number of visitors and see how visitors move around our website when they use it. This helps us to improve the way our website works.
Used to recognise you when you return to our website. This allows us to personalize our content for you and remember your preferences (e.g., your choice of language or region).
Advertising Cookies are used to deliver customized advertising to the user. This can be very convenient, but also very irritating.
Cookies placed by us
Below you can find the non-essential cookies we use listed in accordance with their Name, Description, Lifespan, and Type. Please keep in mind that this list may be updated from time to time.
Google states that it will not associate your IP address with any other data held by Google.
You can disable tracking by Google Analytics with future effect by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser following this link http://tools.google.com/dlpage/gaoptout?hl=en.
What are your choices in relation to cookies?
When you first visit our website, you will be asked to give your consent to cookies being stored on your device. You can accept all cookies or adjust your cookie settings to store only some of the above categories of cookies on your device. You can also refuse all cookies, except for essential cookies, which are cookies that are required for the proper functioning of the website.
Links to other websites
Changes and Questions