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Privacy Policy

Effective: 01/06/2020

At EBLN DMCC, we take privacy and security seriously. This United Kingdom Privacy Notice outlines how we collect your data to operate our business and provide services to you, while keeping your information safe.

EBLN DMCC(the “Company,” “EBLN DMCC” “we,” “our,” or “us”) is committed to protecting the privacy and security of your personal information. This United Kingdom Privacy Notice (“Notice”) explains how we handle and process personal information to operate, improve, and grow what we provide you. By accessing or using our services, systems, websites, and apps (the “Services”), you signify that you have read this Notice and understood that we may collect, store, use, and disclose personal information as described in this Notice. EBLN DMCC is the primary data controller for processing United Kingdom personal information.

Click on the links below to jump to specific sections:

  1. TYPES OF PERSONAL INFORMATION PROCESSED
  2. PURPOSE OF DATA PROCESSING AND LEGAL BASES
  3. DISCLOSURES OF PERSONAL INFORMATION
  4. COOKIES AND TRACKING TECHNOLOGIES
  5. CONTROL OVER YOUR INFORMATION
  6. TRANSFER OF PERSONAL INFORMATION
  7. RETENTION OF PERSONAL INFORMATION
  8. CHANGES TO THE EBLN DMCC POLICY
  9. HOW TO CONTACT US
  1. TYPES OF PERSONAL INFORMATION PROCESSED Personal information You Provide:

We process the following types of personal information when you connect with our Services, like when you sign up for an account, place an order, enroll in a promotion or program, or otherwise engage or communicate with us:

  • Identity Data includes your full name, username, date of birth, gender, and other data on government-issued identification documents.
  • Contact Data includes your email address, mailing address, and telephone numbers.
  • Financial and Identity Data includes your bank account and payment card details, tax or national insurance identifier, and information about your income, account balances, and financial transaction history.
  • Profile Data includes your username and password, your knowledge assessment results, and your interests, preferences, feedback, and survey responses.
  • Usage Information includes information about how you access and use our Services, such as your actions on the Services, including your interactions with others on the Services, photos or media you upload to the Services, and other content you provide (“Usage Information”). We’ll only access your device camera roll and camera with your permission. If you need to update your permissions, you can do so in your device’s settings. Please remember that EBLN DMCC may, but has no obligation to, monitor, record, and store Usage Information in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, to protect and defend our rights and property, or for other reasons relating to our provision of the Services. By using the Services, you consent to the recording, storage, and disclosure of such information you send or receive for these purposes.
  • Contact List Information. With your permission, we may access your contact list on your mobile device or in your email accounts so that you can identify your contacts on the Services and direct the invitation of your contacts. We’ll store and use this information to suggest referrals or connections and for other reasons related to our provision of the Services. We make these recommendations based on your contact list information as well as, with their consent, your contacts’ information if they’re also a EBLN DMCC customer. We’ll only access your contact list information with your explicit permission. If you provide us with personal information from your third-party contacts, it’s your responsibility to ensure that the communication of such data to, and further processing by, EBLN DMCC is lawful. For example, when you provide us with information about your contacts, we may use it to let you know which of your contacts have also signed up for our Services or, at your exclusive direction, send messages to your contacts regarding our Services. We will not send messages to your contacts that are not explicitly directed by you.
  • Additional Information includes information that you submit via focus groups, contests/sweepstakes, job applications, customer support, or other similar means. We may also collect any communications between you and EBLN DMCC and any other information you provide to EBLN DMCC. Personal information Collected Automatically: As is true of many digital platforms, we process certain personal information automatically when you visit our online services, including:
  • Location Data. To help us protect against fraud, provide our services to you, and improve our services, we collect location data, including current and historical information concerning a user’s geographic location, GPS location, transaction location, and IP addresses that they use in conjunction with our Services. We collect and use your location data, for example, to protect against debit card fraud by detecting and declining transactions that may occur far away from your device’s location. We collect information about your location through GPS, Wi-Fi, wireless network triangulation, or other methods in order to obtain your location. We may also approximate your location by your IP Address. We also use the Google Maps API to gather information about your location. Google uses various technologies to determine your location, including IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points, and cell towers (see Google Maps privacy policy to learn more).
  • Usage and Device Data Collected Automatically Through Tracking Technologies. To provide a personalised and enhanced user experience, we, and our third-party partners, automatically collect certain types of usage information when you visit or use our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location identifying technologies, file information, and similar technology (collectively, “Tracking Technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID (that allows us to uniquely identify your browser, mobile device, or your account), and other similar information. We use Tracking Technologies to help ensure that you have a high-quality experience on our Services. We also use Tracking Technologies to aid in the targeted advertising of our services on other platforms. From your device manufacturer, we also may collect the names of other third-party applications that you have downloaded on your device. For more information, please consult the section on Cookies and Tracking Technologies below. Personal information from Other Sources and Third Parties: We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.
  • Third-party data includes data that we collect from business partners, marketing, and vendor partners.
  • Publicly available data includes contact information, employment-related information, and other information from publicly available sources. We may combine this information with the information we collect from you directly. We use this information to contact you, to send you advertising or promotional materials, or to personalise our Services and to better understand the demographics of our users
  1. PURPOSE OF DATA PROCESSING AND LEGAL BASES

We use and otherwise process personal information for the following purposes: Purpose Basis for Processing To provide you with the information, products and services that you request from us; to allow you to participate in interactive features of our Services, when you choose to do so; and to manage our relationship with you, including providing you with the information, products and services that you request from us, and notifying you about changes to our terms or this Notice.

(a) Performance of a contract with you

(b) Necessity to comply with a legal obligation

(c) Necessity for our legitimate interests (for instance, to keep our records updated) To make suggestions and recommendations to you about things that are similar to those that you have inquired about or may otherwise be of interest to you. Necessity for our legitimate interests (to grow our business)

To improve our Services and to ensure that content is presented in the most relevant and effective manner for you and for your device; to administer our Services, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to keep our Services, business and users safe and secure; to comply with applicable laws and regulations; and to protect or exercise our legal rights or defend against legal claims.

(a) Necessity for our legitimate interests (for running and protecting our business; for provision of administration and IT services; for network security and to prevent cybercrime and fraud; in the context of a business reorganisation or group restructuring exercise; to study how people use our Services, to develop the Services, to keep our Services updated and relevant, to grow our business and to inform our communications strategy)

(b) Necessity to comply with a legal obligation For some processing purposes, we may ask your consent (for example, to provide you with marketing information), in which case you will be informed of the purpose in the context of the request for consent. Your consent may subsequently be withdrawn at any time by contacting us as provided in the How to Contact Us section below. Withdrawing consent does not affect the lawfulness of processing based on consent before it is withdrawn. Where we need to collect personal information under the law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In such circumstances, we may cancel the product or service you have with us.

  1. DISCLOSURES OF PERSONAL INFORMATION

We’re committed to maintaining your trust, and we want you to understand when and with whom we may share the personal information. We may share your personal information in the instances described below. For further information on your choices regarding your personal information, see the “Control Over Your Personal information” section below. We do not sell or rent your personal information to third parties for their use in marketing their products and services.

  • Authorised third-party vendors and service providers. We share personal information with certain authorised and vetted contractors, subcontractors, third-party vendors, and service providers who help us run and protect our business. This includes sending emails, conducting business analytics, marketing, and data processing. For example, we may share personal information with service providers that identify and serve targeted advertisements or provide mailing services, tax and accounting services, contest fulfilment, web hosting, or analytics services.
    • EBLN DMCC affiliates. We share personal information with other companies and brands under common ownership or that own EBLN DMCC. These companies will use your personal information in the same way that we do under this United Kingdom Privacy Notice.
  • Business transfers. We may share personal information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, reorganisation, financing, change or control or acquisition of all or a portion of our business by another company or third party, asset sale, initial public offering, or in the unlikely event of bankruptcy or similar proceeding.
  • Legal purposes. We disclose personal information to respond to subpoenas, court orders, legal process, law-enforcement requests, legal claims, or government inquiries and to protect and defend the rights, interests, safety, and security of EBLN DMCC, our affiliates, users, or the public.
  • With your consent. We share personal information for any other purposes disclosed to you with your consent. We may also share information with others in an aggregated or otherwise anonymised form that doesn’t reasonably identify you directly as an individual. Some of the entities to which we disclose personal information (including some of our affiliates and third-party vendors) may be located outside of the European Economic Area [EEA], including in countries such as the United States that do not provide the same level of data protection as your home country. We take appropriate steps to ensure that such personnel and third-party vendors are bound to duties of confidentiality, and the Company implements measures such as standard data protection contractual clauses to ensure that any transferred personal information remains protected and secure. A copy of these clauses can be obtained by contacting us.
  1. COOKIES AND TRACKING TECHNOLOGIES

When you use our Services, cookies and similar Tracking Technologies such as pixel tags may be stored on your browser or device by us and the third parties that may collect information on our Services. Our Services also occasionally use “local shared objects” (also known as “Flash cookies”). We use cookies and the technologies described in this section to help ensure that you have a high-quality experience on our Services. We also use cookies to show you advertising that is relevant to you. We use cookies and Tracking Technologies for the following purposes: a. Essential Cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. These cookies can also help with the safety and security of our Services. b. Preference Cookies – These cookies store information such as your preferred country and language selection, login data, and website preferences. Without these cookies, our Services may not be able to remember certain choices you’ve previously made or personalise your browsing experience by providing you with relevant information. These cookies can also be used to recognise your device so that you do not have to provide the same information more than once. c. Performance Cookies – These cookies collect information about how you use our Services, such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, response times, and error messages. d. Content / Advertising Cookies – These cookies gather information about your use of our Services so we may improve your experience and provide you with more relevant content and advertising. They’re also used to gather feedback through surveys. They remember that you’ve used our Services and help us understand usage of our Services. Some of these cookies are from third parties that collect information (including internet browsing information) about users of our Services across different websites and over time in order to provide advertising (on our Services and elsewhere) based on users’ online activities (so-called “interest-based advertising”) on our Services and elsewhere online. Such companies include Google, Facebook, Twitter, and Snapchat. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Notice. Some of these companies are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here. To learn about how Google processes your personal data and what choices you may have, visit their site here. To control and/or delete cookies, please visit the cookie settings in your browser. Some browsers have options that allow the user to control whether the browser will accept cookies, reject cookies, or notify the user each time a cookie is sent. You may elect to reject cookies by adjusting your settings but doing so will limit the range of features available to you on our Services and other websites. Be sure to read any information provided by your browser developer to understand the limitations of these settings, as they may differ from browser to browser and may not apply to all technologies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email, used our Services, or performed certain functions with it. You may be able to manage Flash cookies by visiting the Adobe website here.

  1. CONTROL OVER YOUR INFORMATION

Access to your Device Data. You may control the mobile app’s access to your device information in your device’s settings. For instance, you can withdraw permission for the app to access your contact list. How to control your communications preferences. You can stop receiving promotional emails from us by clicking on the provided “unsubscribe” link. All unsubscribe requests are processed within 10 business days. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, and technical and security notices). Modifying or deleting your information. You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your personal information, and to request access to, rectification, erasure and portability of your personal information. If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our Services, you can contact us directly at clientservices@eblndmcc.com. We may not be able to modify or delete your information in all circumstances. If you become aware of changes or inaccuracies in your personal information, you should inform us of such changes so that the personal information may be updated or corrected. You may lodge a complaint with a supervisory authority if you believe our processing of your personal information is unlawful.

  1. TRANSFER OF PERSONAL INFORMATION

Your information collected through our Services may be stored and processed in the United Kingdom, United States, or any other country in which EBLN DMCC or its parent, subsidiaries, affiliates, or service providers maintain facilities or conduct business activities. If you’re located in other regions with laws governing data collection and use that may differ from U.K. or U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data-protection laws as your jurisdiction.

  1. RETENTION OF PERSONAL INFORMATION Personal information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws. Our criteria in determining whether to retain or delete data will depend on many factors, such as our legal, contractual, and regulatory obligations, whether the data is helpful in our provision of the Services, the sensitivity of the data, and other factors.
  2. CHANGES TO THIS POLICY This Policy will evolve with time, and when we update it, we’ll revise the “Effective Date” above and post the new Policy. To stay informed of our privacy practices, we recommend you review the Policy each time you visit our Services to stay informed of our privacy practices.
  3. HOW TO CONTACT US You can raise any issues regarding the processing of your personal information by contacting clientservices@eblndmcc.com

© EBLN DMCC 2020. All rights reserved.

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Registered Office: 798, DMCC Business Centre, Level No 1, Jewellery and Gemplex 3, Dubai, United Arab Emirates. EBLN DMCC is a member of the Global Legal Identity Identifier Foundation, a global database of financial firms. EBLN DMCC’s LEIRN is: 8945008XMZ80RQAVSI28. Registered as a Dubai Free-zone company under UAE Law. EBLN DMCC is licensed to trade precious metals and stones, licensed and regulated by the Dubai Multi Commodities Centre and member of the Dubai Gold Exchange and is also a member of the Dubai Chamber of Commerce. License Number: DMCC – 268227. Registration Number: DMCC78715. VAT registration Number: TRN 100052752100003.