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Privacy

 

EBLN DMCC Privacy Policy

post GDPR 2018

Protecting your privacy is important to EBLN DMCC and its wholly owned subsidiaries, EBLN DMCC Ltd. We’re providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive through our website at www.eblndmcc.com and our cloud-based communication service which provides a secure, efficient and robust ecosystem for high-valued information exchange. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services

  1. Collection and Use of Information

Our primary goals in collecting and using information are to provide and improve our Services, to administer your use of the Services (including your Account (as defined below)), to respond to your comments and questions, to use your email address or other contact information to send you information related to the Services and to enable you to enjoy and easily navigate our Services. EBLN DMCC has implemented and will maintain reasonable security controls to protect the confidentiality, integrity and availability of the PII that EBLN DMCC processes. “PII, “Personally Identifiable Information” and “personal data” are all used in this Privacy Policy interchangeably to refer to any data, information, or combination of data and information that is provided by you to EBLN DMCC, and which relates to an identifiable individual.

EBLN DMCC will collect the following information about you:

  • Account Information. To use EBLN DMCC services, you will need to create a trading account (if you are a Direct User) or your company will create an account for you (if you are an Authorized User) (each, an “Account”). When an Account is created we’ll collect certain PII that can be used to identify you, such as your name, date of birth, title, location, email alias, email address and postal address. We will only use such PII for the purposes of providing the Services to you (if you are a Direct User) and your company (if you are an Authorized User). We could also collect other information about you that is not PII, such as Usage Data (as defined below), and this will only be used as described herein.
    • Direct Users: If you create an Account through the Services, we could also collect your gender, date of birth, Post/zip code and other information. We will only use this information for purposes relating to the provision of the Services to you and for improvement of the Services. If your Account is created on behalf of your Business/Company, we will also collect certain information about your business/company, such as your organization’s corporate name, email address, postal address, phone number.
  • Support Information You Give Us: If you contact us for client support, we will collect your name and other content included in the support request, to provide you support.
  • Information Collected Using Cookies and Other Web Technologies. Like many website operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information.
    • “Cookies” are small text files that are placed on your device by a Web server when you access our Services. We use both session Cookies and persistent Cookies to identify that you’ve accessed the Site, logged in to the Services and to tell us how and when you interact with our Services. We also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Please note, however, that if you don’t accept Cookies, you will not be able to access all portions or features of the Services. When you access our Site, certain third-party services providers that we engage could also place their own Cookies on your device. However, third-party service providers cannot place their own Cookies on your device when you access the EBLN DMCC Services. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties.
    • “Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that could be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services and to monitor how many visitors view our Services.
  • Information Related to Use of the Services. Our servers automatically record certain information about how our Services are used (we refer to this information as “Usage Data”). Usage Data could include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the pages or features of our Services to which a User browses and the time spent on those pages or features, frequency with which our Services are used by a User, search terms, and other statistics. We use Usage Data to administer the Services and we analyze (and could engage third parties, who are under an obligation of confidentiality, to analyze) Usage Data to improve, customize, and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences.

Please note that if you decide not to provide us with the PII that we request, you will not be able to access or use all of the features of the Services.

Treatment of PII Following Termination.

  • If you have any questions whatsoever after termination of the relationship with EBLN DMCC whether a trading client or a prospective customer who has visited our sites, please email clientservices@eblndmcc.com
  1. Information that We Share with Third Parties

We will not share any PII that we have collected from or regarding you except as described below, and in the sections of this Privacy Policy entitled “Where We Send Your PII” and “Collection and Use of Information”.

Information Shared with Our Services Providers. We engage certain third-party services providers to work with us to administer and provide a portion of the Services. Such third parties include:

  • customer relationship management software providers, which store your PII globally, to assist us in providing the Services and contacting you;
  • Internet hosting and cloud service provider services

These third-party services providers have access to your PII only for the purpose of performing services on our behalf, and in compliance with applicable laws and regulations (including, without limitation, the CAN-SPAM Act of 2003 and the Privacy Shield (as defined herein), as applicable). Such performance can include the processing of PII, provided that no such third-party service provider has access to your unencrypted Posted Data. Such third parties will be required to maintain the confidentiality of all PII that they process on our behalf and to implement and maintain reasonable security controls to protect the confidentiality, integrity and availability of such PII. For Authorized Users, EBLN DMCC will comply with the terms and conditions between EBLN DMCC and your organization (as the data controller of your PII) in connection with any such onward transfer of your PII. Any such third-party service provider to whom EBLN DMCC transfers PII for processing on behalf of EBLN DMCC is also required to only employ staff who have committed themselves to confidentiality or are under a statutory obligation of confidentiality with respect to your PII. EBLN DMCC will also take reasonable steps to confirm that any such third-party service provider processes such PII in a manner that provides at least the same level of data protection as is provided for by this Privacy Policy and, for Authorized Users, as is required of us pursuant between EBLN DMCC and your organization. Lastly, EBLN DMCC will obligate any such third-party service provider to notify EBLN DMCC if such provider becomes unable to satisfy such data protection obligations, and EBLN DMCC will take reasonable steps to stop and remediate unauthorized or noncompliant processing by such third-party services provider, upon becoming aware of such processing.

Information Shared with Third Parties. We could collect and share aggregated and de-identified information (such that information cannot be identified as the information of a particular user and will therefore not include PII) with third parties for industry research and analysis, demographic profiling and other similar purposes, and for third-party programs to access the Services in a manner that extends the EBLN DMCC user experience and helps us operate and improve the Services.

Information Disclosed in Connection with Business Transactions. Information that we collect from our Users, including PII, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your PII, will be disclosed or transferred to a third-party acquirer in connection with the transaction. The disclosure and transfer of any of your PII to such third-party acquirer will be done in compliance with applicable law and regulation (including but not limited to the Privacy Shield, as the case may be), and only as necessary in order to enable EBLN DMCC or the relevant acquiror to continue to perform services to you or your organization.

Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. In certain circumstances, we will disclose any of your PII to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas), law enforcement requests and national security requests; (ii) to protect our rights and safety and the rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity. In the event of such disclosure or transfer of your PII to public authorities, there is a chance that EBLN DMCC will not be able to require such public authorities to implement and maintain reasonable security controls to protect the confidentiality, integrity and availability of your PII.

Information Shared with Other Users. For Direct Users, the information you list about yourself or, if you are an Authorized User of a company that is subject to the terms of an MSA, that is listed on your behalf by the company in your user profile, including, but not limited to, your profile photo, your organization and your name (collectively “Profile Data”), will be published and viewable to other Users in the EBLN DMCC directory of Users so that other Users can find you using the “Search” feature in the EBLN DMCC Services. For Authorized Users, the content of your Profile Data and its publication in the EBLN DMCC directory of Users will be controlled by your company’s administrator.

  1. Where We Send Your PII

As our Users operate globally, we need to send User PII to different countries in order to provide the Services, and you might send your PII to different countries in the course of submitting Posted Data on the EBLN DMCC to Users in those countries.

  1. Your Choices – EU Users

If you are a User located in the EU, then depending on whether you are a Visitor, a Direct User or an Authorized User, we will offer you certain choices regarding the collection, use and sharing of your PII.

  • Visitors and Direct Users: If you are a Visitor or a Direct User, you have specific rights over the PII that EBLN DMCC controls which you can exercise in specific circumstances, such as:
  • Access: to know whether we process PII about you, to access that PII and find out how we use it and who we share it with;
  • Portability: to receive a subset of the PII we collect from you in a structured, commonly-used and machine-readable format, and to request that we transfer such PII to another party;
  • Correction: to require us to correct PII about you that is accurate or incomplete;
  • Erasure: to request that we erase PII we hold about you in certain circumstances. Note that in cases where we grant your request for deletion, copies of erased PII could remain in archived/backup copies for our records, as we are not always able to delete information from those locations;
  • Restriction: to require us to stop processing the PII we hold about you other than for storage purposes in certain circumstances; and
  • Objection: to object to our processing of PII about you and we will consider your request.

Please contact us at clientservices@eblndmcc.com with such requests. We will respond to your request as soon as we reasonably can and we will attempt to respond to all requests within 60 days of verifying your identity.

  • Authorized Users: If you are an Authorized User, the PII associated with your Account and your Profile Data is managed by your company administrator. EBLN DMCC can only act on the instructions of you or your company, so you must contact them directly to exercise any rights over your PII. For questions about how you can exercise your rights over your PII, please contact the appropriate EBLN DMCC representative and they will be able to provide more information about how your request will be handled.
  1. Questions; Complaints; Other

If you have any questions about this Privacy Policy or our treatment of your information, please write to our General Counsel by email at clientservices@eblndmcc.com or by postal mail at:

For the purposes of EU data protection laws, our representative in the EU is EBLN DMCC 41 Southgate Street, Winchester, Hampshire, SO23 9EH, United Kingdom.

You can at any time submit a complaint, personal data access request or communicate any other issues arising under the Privacy Shield with respect to your use of the Services to EBLN DMCC, 798 DMCC Business Centre, Level No 1, Jewellery and Gemplex 3, Dubai, UAE

You must be at least 18 years of age to use the Services. Our Services are not directed to individuals under 18 and we do not knowingly collect PII from individuals under 18. If we learn that we have collected PII of an individual under 18 we will take steps to delete such information from our files.

  1. Revisions to this Privacy Policy

Any PII that is collected via our Services is processed in accordance with the Privacy Policy in effect at the time such information is collected. We could revise this Privacy Policy from time to time. We’ll update the “Last Updated” date above to indicate when the Privacy Policy was last materially changed.

If we make any material changes to this Privacy Policy that adversely impact or decrease the privacy and security of PII we’ll notify you as follows:

  • Visitors and Direct Users: We’ll post them on the Services.
  • Authorized Users: We’ll send your company a notification at least 30 days prior to such change taking effect and provide your company with a link to such updated Privacy Policy so they can notify you (or, promptly upon request, we’ll provide you with such updated Privacy Policy).

Legal Basis Table

Please note that this table is only for Visitors and Direct Users located in the EU and applies where EBLN DMCC is the data controller. For Authorized Users, please contact your company for further information about its legal basis of processing.

Data FieldProcessing PurposeLegal Basis

Account Information
.to notify you about changes to our services.
.to provide you with user support;
.to enforce our terms, conditions and policies;
.to communicate with you;
.to administer the EBLN DMCC Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
Contract
Legitimate Interests (to make sure that our Services function properly and meet your needs)
Support information you give us.to make sure that the Services work for you and to provide you with user supportInformation collected using cookies and other web technologies
Information collected using cookies and other web technologies.to make sure that the Services work properly for you
Consent
Usage Data· to fulfill our contract with you
· to improve, customize and enhance our Services
Contract
Legitimate Interests (to make sure that our Services function properly and meet your needs)
Posted Data· to fulfill our contract with youContract
Information sent by your mobile device· to make sure that the Services work properly for youLegitimate Interests (to make sure that our Services function properly and meet your needs)
Location information· to provide you with location-based services and improve and personalize our Services to youConsent

© EBLN DMCC 2018. All rights reserved. Legal.

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Registered Office: 798, DMCC Business Centre, Level No 1, Jewellery and Gemplex 3, Dubai, United Arab Emirates. Registered as a Dubai Free-zone company under UAE Law. Licensed to trade precious metals , Licensed and regulated by the Dubai Multi Commodities Centre and member of the Dubai Gold Exchange. License Number: DMCC – 268227