Privacy Policy
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and explains Your privacy rights and how the law protects You under both the laws of the United Arab Emirates and, where applicable, the European Union.
By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
Interpretation
The words with capitalised initial letters have meanings defined under the following conditions. The following definitions shall have the same meaning whether they appear in singular or plural.
Definitions
For the purposes of this Privacy Policy:
· Account means a unique account created for You to access our Service or parts of our Service.
· Affiliate means an entity that controls, is controlled by or is under common control with a party.
· Company (“the Company”, “We”, “Us” or “Our”) refers to Liberta Consulting Group FZE, licensed under UAQ Free Trade Zone license number 2627 (registered address: Al Shmookh Business Center, One UAQ, UAQ Free Trade Zone, Umm Al Quwain, United Arab Emirates), and the Dubai Department of Economy and Tourism license number 1304151 (registered address: The Binary Tower, Office 1807, Business Bay, Dubai, United Arab Emirates).
· Country refers to the United Arab Emirates.
· Applicable Data Protection Law refers to UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and its Executive Regulations and, where relevant, the EU General Data Protection Regulation (GDPR).
· Data Controller refers to the Company as the entity that determines the purposes and means of processing Personal Data.
· Device means any device that can access the Service.
· GDPR refers to the EU General Data Protection Regulation.
· Personal Data means any information relating to an identified or identifiable individual.
· Service refers to the Website.
· Service Provider means any natural or legal person who processes the data on behalf of the Company.
· Usage Data refers to data collected automatically through the Service.
· Website refers to libertacg.com
· You means the individual or legal entity using the Service.
· Cookies / Tracking Technologies: Our Website does not use cookies for advertising or behavioural tracking. However, certain essential or analytics tools, such as Google Analytics, may use cookies or similar technologies to collect aggregate usage data.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide certain personally identifiable information, including:
· Email address
· First and last name
· Phone number
· Usage Data
Usage Data
Usage Data is collected automatically when using the Service and may include information such as IP address, browser type, pages visited, time spent on pages, device identifiers, and diagnostic data.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
· To provide and maintain our Service, including to monitor the usage of our Service.
· To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
· For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
· To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
· To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
· To manage Your requests: To attend and manage Your requests to Us.
· For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
· For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
Disclosure to UAE Governmental, Regulatory and Free Zone Authorities
To comply with UAE legal, regulatory, licensing, immigration and financial requirements, We may share Your Personal Data with UAE governmental, regulatory and free zone authorities, including but not limited to those responsible for company licensing, immigration, taxation, banking compliance and other regulatory matters.
We may share Your personal information in the following situations:
· With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
· For business transfers: We may share or transfer Your personal 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.
· With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
· With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
· With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
· With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy. We also comply with mandatory retention periods required by UAE corporate, regulatory, licensing, financial and immigration rules.
Usage Data is generally retained for a shorter period unless required for security or legal obligations.
Transfer of Your Personal Data
Your Personal Data may be transferred outside the United Arab Emirates in accordance with the cross-border transfer rules under UAE PDPL. Transfers occur only to countries that provide an adequate level of protection or through approved contractual safeguards.
Where the GDPR applies, transfers of Personal Data outside the European Economic Area (EEA) are made on the basis of an adequacy decision of the European Commission or using appropriate safeguards such as standard contractual clauses or equivalent contractual protections.
By submitting Your information and using the Service, You acknowledge that such international transfers may occur in accordance with Applicable Data Protection Law.
Delete Your Personal Data
You have the right to request deletion of the Personal Data that We have collected about You. You may update, amend or delete Your information from within Your Account or by contacting Us. Certain data may be retained where legally required.
Disclosure of Your Personal Data
Your Personal Data may be disclosed in connection with a merger, acquisition, asset sale, or where required by law or government authorities. We may also disclose Your data to protect the Company’s legal rights, prevent wrongdoing, or ensure public safety.
Security of Your Personal Data
We take reasonable measures to protect Your Personal Data. However, no method of electronic storage or transmission is completely secure.
Processing of Your Personal Data by Service Providers
Third-party Service Providers may process Your Personal Data in accordance with their own privacy policies.
Analytics
Google Analytics may be used to monitor usage of the Service. You may opt out using the Google Analytics browser add-on.
Email Marketing
We may use Your Personal Data to send You newsletters or promotional content. You may opt-out at any time. We may use Mailchimp for email delivery.
GDPR Privacy
Legal Basis for Processing Under GDPR
Where the GDPR applies, We process Personal Data on the following legal bases:
• Your consent, where you have clearly agreed to a specific processing purpose.
• Performance of a contract or pre-contractual steps, including responding to your enquiries or providing our services.
• Compliance with a legal obligation to which We are subject.
• Protection of vital interests, where processing is necessary to protect your vital interests or those of another person.
• Performance of a task carried out in the public interest, where applicable.
• Our legitimate interests, provided such interests are not overridden by your rights and freedoms, for example in improving our services, preventing abuse of the Service, or defending our legal rights.
If GDPR applies, You have the rights to access, correct, delete, restrict, object to processing, portability, and to withdraw consent. You may also lodge a complaint with an EU authority.
You may exercise Your GDPR rights by contacting us at info@libertacg.com.
UAE PDPL Privacy
Legal Basis for Processing Under UAE Law
We process Personal Data under UAE Federal Decree-Law No. 45 of 2021 based on:
• Your consent
• Performance of a contract or pre-contractual steps
• Compliance with a legal obligation
• Protection of public interest or security
• Our legitimate interests, provided they do not override Your rights
Your Rights Under UAE PDPL
Under UAE PDPL, You have the right to:
• Access Your Personal Data
• Request correction of inaccurate data
• Request deletion of data
• Request restriction or cessation of processing
• Object to automated processing or profiling
• Request data portability within the UAE
• Withdraw consent
• Lodge a complaint with the UAE Data Office
Exercising Your PDPL Rights
You may exercise Your rights by contacting Us. We may verify Your identity before responding.
Personal Data Breach Notification
In the event of a Personal Data breach that may impact Your privacy or security, We will notify You and the UAE Data Office in accordance with UAE PDPL requirements.
Children’s Privacy
Our Service does not address individuals under 13. If We learn that We have collected Personal Data from a minor without parental consent, We will delete it.
Links to Other Websites
We are not responsible for the privacy practices or content of third-party websites.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time. Changes become effective when posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us at:
info@libertacg.com