Privacy Policy

Privacy Policy | Cookie Policy

Thank you for choosing to be part of our community at ASSA Advidors (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at info@assaadvisors.com.

When you visit our website, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

Table Of Contents
  • What Information Do We Collect?
  • How Do We Use Your Information?
  • Will Your Information Be Shared With Anyone?
  • Do We Use Cookies And Other Tracking Technologies?
  • Do We Use Google Maps?
  • Is Your Information Transferred Internationally?
  • How Long Do We Keep Your Information?
  • How Do We Keep Your Information Safe?
  • Do We Collect Information From Minors?
  • Do We Make Updates To This Policy?
  • How Can You Contact Us About This Policy?
What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us such as name, address, contact information and company information.

We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services when participating in activities on the Sites or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we collect can include the following:

Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collectedus

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites.

We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

How Do We Use Your Information?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To send you marketing and promotional communications for Business Purposes. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).

To send administrative information to you for Business Purposes and/or possibly for Contractual. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

Deliver targeted advertising to you for our Business Purposes. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

Administer prize draws and competitions for our Business Purposes. We may use your information to administer prize draws and competitions when you elect to participate in competitions.

Request Feedback for our Business Purposes. We may use your information to request feedback and to contact you about your use of our Sites. To protect our Sites for Business Purposes. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).

To enforce our terms, conditions and policies for Business Purposes and/or possibly for Contractual.

To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.

Will Your Information Be Shared With Anyone?

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We only share and disclose your information in the following situations: Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

With your Consent. We may disclose your personal information for any other purpose with your consent.

Do We Use Cookies And Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

Do We Use Google Maps?

In Short: Yes, we use Google Maps for the purpose of providing better service. This website, mobile application, or Facebook application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link.

By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. You agree to allow us to obtain or cache your location. You may revoke your consent at any time. We use information about the location in conjunction with data from other data providers.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Sites. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

Is Your Information Transferred Internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States of America, India, and the United Arab Emirates. If you are accessing our Sites from outside the United States of America, India, and United Arab Emirates, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in United States, India, United Arab Emirates, and other countries.

If you are a resident of the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will, however, take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law. The European Parliament issued the General Data Protection Regulations (‘Regulations’) for the protection of natural persons with regard to the processing of personal data and on the free movement of such data. These Regulations have become effective from May 28, 2018. Few of the important aspects of the Regulations are summarized hereinafter:

Objectives of GDP Regulations

The Regulation has the following objectives:

  • Protects fundamental rights and freedom of natural persons, in particular, their right to protection of their personal data;
  • Free movement of personal data within the union, it can neither be prohibited nor restricted for reasons of protection of natural persons;
Geographical Reach and Applicability

The Regulations applies to:

  • This Regulation applies to the processing of personal data wholly or partly by automated means or otherwise.
  • a person who processes personal data for its utilization in its activities and to the person who processes such personal data within the European Union;
  • the processing of personal data of persons who are in the European Union, whether the controller of such data or the processor is within the European Union or not, if such processing is related to:
  • (a)     the offering of goods or services, irrespective of whether a payment of the data subject is required, to such data subjects in the Union; or

    (b)    the monitoring of their behaviour as far as their behaviour takes place within the Union.

  • the processing of personal data by a controller not established in the Union, but in a place where Member State law applies by virtue of public international law.

Regulation does not apply to protection of personal data when:

  • in course of activity which falls outside the scope of European Union law.
  • by the member states when carrying out activities which are specifically stated to be outside the scope of European Union.
  • by a natural person in the course of purely personal or household activity.
  • by government authorities for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties including the safeguarding against and the prevention of threats to public security.
Principles for processing

The following principles should be considered for processing of the personal data of the data subject:

  • it should be processed lawfully, fairly and in a transparent manner in relation to individuals;
  • it should be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  • processing of data for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  • the data should be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  • every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
  • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
  • personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals.
  • data has to be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
Consent – Whose & How

The Regulations provide that the Consent of the data subject is necessary for processing the data and following should be considered while taking the consent:

  • consent under the GDPR must be a freely given, specific, informed and unambiguous indication of the individual’s wishes:
  • there must be some form of clear affirmative action – or in other words, a positive opt-in – consent cannot be inferred from silence, pre-ticked boxes or inactivity;
  • consent must also be separate from other terms and conditions, and you will need to provide simple ways for people to withdraw consent;
  • public authorities and employers will need to take particular care to ensure that consent is freely given.
Children’s Personal Data

The Regulations contain new provisions intended to enhance the protection of children’s personal data which are stated hereinafter:

  • privacy notices for children should be written clearly and in a plain manner which is understood by children;
  • online services offered to children would require consent from a parent or guardian to process the child’s data;
  • if consent is the basis for processing the child’s personal data, a child under the age of 16 can’t give that consent themselves and instead consent is required from a person holding ‘parental responsibility’.
Individual Rights

The Regulations provides the following rights for individuals:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to object
  • The right in relation to automated decision making and profiling.
How Long Do We Keep Your Information?

The Regulations applies even if the data is concerning persons who are within European Union irrespective of the fact where the person for whom data is processed and who processes the data;

The Regulations also applies if data is concerning monitoring of the behavior of a data subject within the European Union;

If because of either of the aforementioned requirement, these Regulations are applicable, a consent would have to be obtained, in a manner which is explicit, from the person to use data related to him for a particular purpose.

The data subject also has certain rights such as erasure of data, restricting of processing and object to the processing of his data. These rights have to be made available to him and any non-compliance would result in damages.

Any dealing with children would require consent from their parents or guardians.

What Information Do We Collect?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites.

If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at info@assaadvisors.com.

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

How Can You Contact Us About This Policy?

You can contact us by dropping an email at info@assaadvisors.com.

Cookie Policy

This Cookie Policy explains how ASSA Advisors (“ASSA Advisors”, “we”, “us”, and “ours”) use cookies and similar technologies to recognize you when you visit our websites at https://www.assaadvisors.com/, (“Websites”). It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases, we may use cookies to collect personal information, or that becomes personal information if we combine it with other information. In such cases, our Privacy Policy (https://www.assaadvisors.com/privacypolicy) will apply in addition to this Cookie Policy.

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, ASSA Advisors) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content, and analytics). The parties that set these third party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use cookies?

We use first and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties. Third parties serve cookies through our Websites for advertising, analytics and other purposes. This is described in more detail below.

The specific types of first and third party cookies served through our Websites and the purposes they perform are described below (please note that the specific cookies served may vary depending on the specific Online Properties you visit):

Analytics and customization cookies:

These cookies collect information that is used either in aggregate form to help us understand how our Website are being used or how effective our marketing campaigns are, or to help us customize our Websites for you.

  • Who serves these cookies:
  • Cookie provider: Google Analytics

Website URL: http://analytics.google.com

  • How to refuse: To refuse these cookies, please follow the instructions below under the heading “How can I control cookies?”. Alternatively, please visit the relevant opt-out link below:
  • Cookie provider: Google Analytics

Opt-out Link: https://tools.google.com/dlpage/gaoptout

Advertising cookies:

These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.

  • Who serves these cookies:
  • Cookie provider: Google Adwords Website URL: https://adwords.google.com
  • How to refuse: To refuse these cookies, please follow the instructions below under the heading “How can I control cookies?”. Alternatively, please visit the relevant opt-out link below:
  • Cookie provider: Google Adwords

Website URL: https://adssettings.google.com

What about other tracking technologies, like web beacons?

Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Websites or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Websites to another, to deliver or communicate with cookies, to understand whether you have come to our Websites from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

Do you serve targeted advertising?

Third parties may serve cookies on your computer or mobile device to serve advertising through our Websites. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other details that directly identify you unless you choose to provide these.

How can I control cookies?

You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices or http://www.youronlinechoices.com.

How often will you update this Cookie Policy?

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please, therefore, re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Policy indicates when it was last updated.

Where can I get further information?

If you have any questions about our use of cookies or other technologies, please email us at info@assaadvisors.com or by post to:

ASSA Advisors DWC-LLC

A3 Business Center, Dubai World Central,

PO Box 390667,

Dubai, UAE

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