CPX is committed to complying with applicable data protection laws and requirements with regard to collection, usage and safety of personal information received from individuals, customers, suppliers, business partners, employees and other people with whom it deals in order to carry out its business.
CPX collects and processes all Personal Information 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 Information 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 Information 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 Information collected and processed by us is accurate and, where necessary, kept up to date.
5) Data Retention - Personal Information is kept in a form which permits identification of individuals for no longer than is necessary for the purposes for which the Personal Information is processed.
6) Technical and organizational security and confidentiality - Personal Information is processed in a manner that ensures appropriate security of the Personal Information, 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.
"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.
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, even when linked to other information.
3.1 What type of Personal Information does CPX collect?
3.1.1 We will collect the following types of personal information about you when you complete an online form on our web site.
3.1.2 As part of CPX ’s recruitment process, we may also collect the following information from applicants for the review and evaluation of their application:
3.2 Why does CPX collect and use Personal Information?
CPX collects and uses your Personal Information 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
3.3 How does CPX obtain your consent?
Sometimes CPX may requests your consent before processing your Personal Information. If so, the form of consent sought by CPX may vary, depending upon the circumstances and the type of Personal Information 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 Information. CPX will always seek express consent when the Personal Information is likely to be considered sensitive. Sensitive Personal Information 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 Information and inform the Customer of the use that will be made of the Personal Information. 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 Information with your consent up to that point is unlawful. This includes your right to withdraw consent to us using your Personal Information for marketing purposes. If you wish to withdraw your consent to certain collection, retention, use or disclosure of Personal Information, please contact CPX , at [email protected]
3.4 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 Information necessary, or you refuse or withdraw your consent for the processing of your Personal Information, 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. We will explain the impact on you at the time, to help you with your decision.
3.5 Who does CPX share Personal Information with?
We share your Personal Information with trusted third parties where we have retained them to provide products and/or services that you or our customer have requested. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
We share your Personal Information 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. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
We share your Personal Information 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 Information will be disclosed to such entity. Also, if any bankruptcy or reorganization 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 Information 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 Information. 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 Information provided to third parties may be used only for the purpose stipulated.
3.6 Will your Personal Information be transferred outside of the country?
In the event that a third party service provider is located in a foreign country, your Personal Information 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 Information through the laws of the foreign country. Whenever your Personal Information is transferred to a foreign country, we will ensure that appropriate safeguards are put in place in relation to that transfer.
3.7 How does CPX safeguard your Personal Information?
The nature of the safeguards varies depending on the sensitivity of the Personal Information, the scope of the Personal Information, and the method of storage of that information. More sensitive types of Personal Information will be safeguarded by a higher level of protection, such as encryption. If you would like more information about the safeguards we have in place, please contact us by e-mailing [email protected]
3.8 How long does CPX retain your Personal Information?
Personal Information collected by CPX will be retained in accordance with applicable legal requirements. Personal Information shall be automatically deleted, if the data is no longer required and there is no legal requirement to maintain that information.
3.9 What are your rights?
By law you have a number of rights when it comes to your Personal Information. Further information and advice about your rights can be obtained by the data protection regulator in your country.
|Rights||What does this mean?|
|1. 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).|
|2. The right to be informed||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.|
|4. The right to rectification||You are entitled to have your information corrected if it’s inaccurate or incomplete.|
|5. The right to erasure||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.|
|6. 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.|
|7. 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.|
|8. 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 protected]
In certain circumstances, CPX may not be able to provide access to all the Personal Information it holds, for example, when the disclosure would reveal confidential business information; if the Personal Information is protect
3.10 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.
3.11 Your role in protecting your Personal Information:
CPX does its best to protect and safeguard Personal Information and we believe there are safeguards you should take as well. Do not share your Personal Information 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 Information in your email inbox or on Webmail.