"CPX ", "we", "us” or "our": Means CPX and each of its affiliates in the UAE, and worldwide, as they may exist from time to time.
"Customer", "you" or "your": Means an individual who: (a) subscribes for, uses or receives, has used or received, or applies to use or receive CPX 's products and/or services; (b) corresponds with CPX ; and/or (c) is a user of this website.
Personal data: Means information that identifies you personally, for example your name, photograph, account number, e-mail address, payment information, user logs or certain numbers associated with your equipment (for example IP address), if CPX can link such information or numbers to you. It does not include aggregate or anonymised information that cannot identify you
2. Our commitment to you
CPX is committed to complying with applicable data protection laws and requirements with regard to processing of personal data received from individuals, customers, suppliers, business partners, employees and other people with whom we deal in order to carry out our business.
CPX collects and processes all personal data in accordance with the following principles.
1) Fairness, lawfulness and transparency - Personal Information is processed lawfully, fairly and in a transparent manner.
2) For specific lawful purpose - personal data is only collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes.
3) Relevant and not excessive - personal data collected and processed by us is adequate, relevant and limited to that which is necessary in relation to the purposes for which it is processed.
4) Accurate and up to date - personal data collected and processed by us is accurate and, where necessary, kept up to date.
5) Data Retention - personal data is kept in a form which permits identification of individuals for no longer than is necessary for the purposes for which the personal data is processed.
6) Technical and organisational security and confidentiality - personal data is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
7) Accountability – CPX is responsible for and can demonstrate compliance with the above principles.
3.What type of personal data does CPX collect?
3.1 We will collect the following types of personal information about you when you complete an online form on our web site.
- Full name
- Job Title
- E-mail address
- Company name
- Contact number
- Your message to us
During your interaction with CPX's websites, we may use a browser feature called a "cookie" to collect information anonymously and track your patterns on our websites. A cookie is a small text file containing a unique identification number that identifies your browser to our computers each time you visit one of our websites. Cookies tells us which pages of our websites are visited and how many people visited each web page. This helps us to enhance the on-line experience of visitors to our websites. Cookies also serve to identify your computer so that your preferences can be saved for future visits and advertising based on your previous interaction with the site. CPX works with third parties that use these cookies to help us with such traffic management, research and analytics.
4. Why does CPX collect and use Personal data?
CPX collects and uses your Personal data for the following purposes:
a. To establish and maintain a responsible commercial and legal relationship with you;
b. Where we have a legitimate interest, such as to provide you with our products and/or services;
c. For research and statistical purposes, to understand your needs as a Customer and your eligibility for products and services
d. To recommend particular products, services and opportunities to its Customers;
e. To provide information to you about developments and new products;
f. To develop, enhance and market products and services and/or provide products and services to its Customers;
g. To provide customer support;
h. To meet CPX 's legal and regulatory requirements
i. To send you information, updates you've requested; and
5. How does CPX obtain your consent?
Sometimes CPX may requests your consent before processing your Personal data. If so, the form of consent sought by CPX may vary, depending upon the circumstances and the type of Personal data processed. In determining the form of consent obtained from you, CPX takes into account the sensitivity of the information and your reasonable expectations, so that you understand the nature, purpose and consequences of the collection, use and/or disclosure of your Personal data. CPX will always seek express consent when the Personal data is likely to be considered sensitive. Sensitive Personal data means information about an individual’s: race; ethnic origin; politics; religion; trade union membership; genetics; biometrics; health; sex life; or sexual orientation.
Consent may be obtained in any one of the following ways:
a. An application form may be used to seek consent, collect Personal data and inform the Customer of the use that will be made of the Personal data. By completing and signing the form, the Customer is giving consent to the collection and the specified uses;
b. A series of tick boxes may be used to allow the Customer to request that their names and addresses are not given to other organizations;
c. Orally when information is collected over the telephone; or
d. At the time a Customer uses a product or service
You may withdraw your consent at any time, although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful. This includes your right to withdraw consent to us using your personal data for marketing purposes. If you wish to withdraw your consent to certain collection, retention, use or disclosure of personal data, please contact CPX at email@example.com
6. What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary, or you refuse or withdraw your consent for the processing of your personal data, where this information is necessary for us to provide a product and/or service to you, we may not be able to provide you with that particular product and/or service.
7. Who and Why does CPX share personal data with?
We share your personal data with trusted third parties where we have retained them to provide products and/or services that you or our customer have requested.
We share your personal data with third parties who perform functions on our behalf and who also provide products and/or services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function co-coordinators.
When we share personal data with these parties, we require that they use or disclose that personal data only as instructed by us and in a manner consistent with this Privacy Notice. We also enter into contracts with these parties to make sure they respect the confidentiality of your personal data and have appropriate data security measures in place.
We share your personal data with our other group companies for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your personal data will be disclosed to such entity. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible it will be sold or transferred to third parties.
Where required we share your personal data with other third parties: to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the our website, our business or the public.
CPX does not sell your personal data. Except as required or permitted by law, when disclosure is made to a third party other than a CPX partner or associate, or a third party service provider, the consent of the individual shall be obtained Such third parties are provided only with such information as is necessary in the circumstances. personal data provided to third parties may be used only for the purpose stipulated.
8. Will your personal data be transferred outside of the country?
In the event that a third party service provider is located in a foreign country, your personal data may be processed and stored in such other foreign country. In such circumstances, the governments, courts or law enforcement or regulatory agencies of that country may be able to obtain access to your personal data through the laws of the foreign country. Whenever your personal data is transferred to a foreign country, we will ensure that appropriate safeguards as per applicable data protection laws are put in place in relation to that transfer.
9. How does CPX safeguard your personal data?
The nature of the safeguards varies depending on the sensitivity of the personal data, the scope of the personal data, and the method of storage of that information. More sensitive types of personal data will be safeguarded by a higher level of protection, such as encryption.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
If you would like more information about the safeguards we have in place, please contact us by e-mailing firstname.lastname@example.org.
10. How long does CPX retain your personal data?
personal data collected by CPX will be retained in accordance with applicable legal requirements. personal data shall be automatically deleted, if the data is no longer required and there is no legal requirement to maintain that information.
11. What are your rights?
By law you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained by the data protection regulator in your country.
Rights-What does this mean?
- The right to object to processing
You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
- The right to rectification
You are entitled to have your information corrected if it’s inaccurate or incomplete.
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
- The right to restrict processing
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
- The right to data portability
You have rights to obtain and reuse your personal information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
- The right to withdraw consent
You have the right to withdraw your consent for processing your data at any time. Your right to revoke you consent is only applicable when the processing of your data is based on consent.
- The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator.
You may exercise any of the above rights by submitting a request to email@example.com.
In certain circumstances, CPX may not be able to provide access to all the personal data it holds, for example, when the disclosure would reveal confidential business information.
12. How can I challenge compliance and offer suggestions?
CPX will investigate all complaints and respond to all questions asked by you. If a complaint is found to be justified, CPX will take appropriate measures to resolve the complaint, which may include amending its policies and procedures.
13. Your role in protecting your Personal Information:
Please remember that CPX's Privacy Notice and our use of your personal data only applies to the information you provide. CPX does its best to protect and safeguard personal data and we believe there are safeguards you should take as well. Do not share your personal data with any third party unless you clearly understand the purpose of the request and you know with whom you are dealing. Do not keep sensitive personal data in your email inbox or on Webmail.
14.Children Data Processing Disclaimer
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, 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 Services. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at firstname.lastname@example.org.